AML / Financial Crime

Crypto Exchange

Investment Management Capital Markets & Trading

🇭🇰 SFC Consultation high

May 26th 2026

FSTB and SFC conclude consultations on virtual asset advisory and management regimes

No description available.

AI Analysis

The Financial Services and the Treasury Bureau (FSTB) and the Securities and Futures Commission (SFC) have concluded their consultation on **new virtual asset (VA) advisory and management regimes**, confirming that these will be legislated under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO, Cap. 615) and aligned with existing Type 4 and Type 9 regimes under the Securities and Futures Ordinance. This materially expands Hong Kong’s VA perimeter: firms providing VA investment advice or VA portfolio management will be brought into a statutory licensing and AML/CTF framework comparable to traditional securities and asset management, with an expected bill to be introduced into LegCo in 2026.

What Changed

- The Hong Kong Government and SFC have confirmed that dedicated regulatory regimes for VA advisory services and VA management services will be created under the Anti-Money Laundering and...
The regulatory scope and standards of the VA advisory regime will be aligned with Type 4 “advising on securities” regulated activity under the Securities and Futures Ordinance, applying a “same...
The regulatory scope and standards of the VA management regime will be aligned with Type 9 “asset management” regulated activity under the Securities and Futures Ordinance, implying broadly...
The consultation received broad market support across 51 responding stakeholders, and the SFC has treated this as a mandate to proceed to finalisation of the detailed legislative proposals and...
The new VA advisory and management regimes will sit alongside existing and proposed VA regimes for: VA trading platforms, stablecoin issuers, VA dealing and VA custody, forming an end-to-end...

Suggested Considerations

Conduct a gap analysis comparing current or planned virtual asset advisory and management activities against Type 4 and Type 9 requirements under the Securities and Futures Ordinance to identify where equivalent capabilities, controls and governance will be required under the new VA regimes.
Map all group entities and business lines that provide VA-related advice, research, recommendations or portfolio management to clients in or from Hong Kong, and determine which entities will need licensing or authorisation under the forthcoming AMLO-based regimes.
Initiate early engagement with the SFC (e.g. via pre-application meetings or WINGS enquiries) to clarify how existing licences, business models and cross-border arrangements will be treated under the new VA advisory and management regimes.
Review and, where necessary, enhance AML/CTF frameworks, including customer due diligence, transaction monitoring, sanctions screening and ongoing review procedures, to ensure they are robust enough for VA-specific risks anticipated under AMLO-based regulation.
Update internal policies and procedures on suitability, product due diligence, risk disclosure, conflicts of interest and best execution to explicitly cover VA advisory and VA management services in line with standards applied to traditional securities and funds.

Key Dates

19 February 2025

- SFC issues its ASPIRe roadmap, with “Access” identified as one of five pillars and VA regulatory expansion flagged as a strategic priority

27 June 2025

Sectors:

Topics:

Asset Manager

🇺🇸 CFTC News

May 21st 2026

CFTC and National Hockey League Sign MOU Related to Integrity in Professional Hockey

No description available.

Sectors:

Topics:

Broker DealerAll Firms

🇦🇪 ADGM News

May 21st 2026

Adgms Fsra And Hellenic Capital Market Commission Sign Mou To Strengthen Cross Border Regulatory Cooperation

Sectors:

Topics:

All Firms

🇦🇪 ADGM News

May 21st 2026

On 12 May 2026, the Swiss Financial Market Supervisory Authority FINMA launched the consultation on the partially revised AMLO-FINMA. The consultation will go on until 9 June 2026.

Deadline: 9 June 2026

Sectors:

AML / Financial Crime Technology & Cyber Market Abuse / Surveillance

Topics:

All Firms

🇱🇺 CSSF News

May 12th 2026

List of members of the Expert Working Group Specialised PFS regarding AML/CFT (Updated)

No description available.

Sectors:

Topics:

All Firms

🇱🇺 CSSF News

May 12th 2026

Terms of reference of the public-private partnership PFS SP related to AML/CFT (only in French) (Updated)

No description available.

Sectors:

Topics:

All Firms

Banking & Credit Capital Markets & Trading

🇬🇧 FCA Speech

May 11th 2026

Laying the foundation for confidence

Speech by Sarah Pritchard, deputy chief executive, at the Investment Association's Private Markets Summit 2026. Headlines are always a tough read when funds run into difficulty.And lately, the language has been stark.Some have even asked if private credit has a canary in the coal mine.That’ll make you sit up a bit straighter, won’t it?But in this moment, it’s important to remember that stress in markets is normal – and okay, as long as the system stays resilient.Private markets, done well, ca...

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Technology & Cyber

All Firms

AML / Financial Crime Technology & Cyber Authorisation & Licensing

🇬🇧 FCA News

May 11th 2026

Restrictions imposed on Kingscrown Finance Limited

Kingscrown Finance Limited (Kingscrown) has stopped onboarding new customers or undertaking new business with existing customers – including extending existing credit. Kingscrown, which was incorporated in 2014, provides lending for business and investment purposes, including property investment, buy-to-let and house in multiple occupation (HMO) finance.The voluntary restrictions on Kingscrown’s business came into effect on 21 April 2026. Kingscrown has never been authorised by or registered ...

Sectors:

Banking & Credit

Topics:

All Firms

Capital Markets & Trading Payments & E-Money

🇬🇧 FCA News

May 8th 2026

Convicted money launderer sentenced to extra prison time

A convicted money launderer has been sentenced to an additional 499 daysin prison for failing to fully pay the money owed under a Confiscation Order. In 2021,RichardFaithfull,now36,wassentenced to5 years and 10 monthsin prisonfor laundering £2.5 million, following a prosecution brought by the Financial Conduct Authority (FCA).He was part of a trans-national organised crime group which laundered the proceeds of at least 7 overseas investment frauds.Mr Faithfullis required topay back £529,961,b...

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Technology & Cyber

All Firms

Wealth & Private Banking Capital Markets & Trading

🇬🇧 FCA News

May 7th 2026

Kanda Products & Services Ltd enters liquidation

On 6 May 2026, Kanda Products and Services Ltd (Kanda) entered liquidation. Philip Harris and Neville Side of FRP Advisory Trading Limited have been appointed as Joint Liquidators. Kanda is authorised by the FCA as a credit broker. It operated a network of around 700 introducer appointed representatives, mainly tradespeople who introduced consumers to finance for home improvement and other goods and services.On 16 February 2026, Kanda agreed to a voluntary requirement with the FCA which restr...

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Technology & Cyber

Broker Dealer

🇱🇺 CSSF News

May 7th 2026

Launch of the Luxembourg AML/CFT official portal by the Minister of Justice on 6 May 2026 (only in French)

No description available.

Sectors:

Topics:

All Firms

Banking & Credit Investment Management Capital Markets & Trading Payments & E-Money Crypto & Digital Assets Consumer Credit

🇮🇪 CBI Enforcement low

May 7th 2026

“Capital, Competition, and Complexity – regulatory perspectives on the regulatory debate” – Remarks by Deputy Governor Mary-Elizabeth McMunn

Introduction Good morning – I am delighted to be here, and many thanks to Brian and the BPFI for hosting us. 1 I very much look forward to the discussion, and to hearing from you all today, but before I do I would like to set out some reflections on a number of topics which are currently high on the regulatory agenda. While the discussion is multifaceted, and tied up with a regulatory cycle which has turned, an economic one which has become more challenging, not to mention a renewed focus by ...

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Prudential / Capital Requirements

All Firms

🇸🇬 MAS News

May 6th 2026

Singapore has a robust framework for combatting financial crime according to international body

The Financial Action Task Force published a peer evaluation report of Singapore today, which strongly affirmed that Singapore has a robust and effective framework and process to counter money-laundering, terrorism financing and proliferation financing.

Sectors:

Topics:

All Firms

🇦🇪 ADGM News

May 4th 2026

Sectors:

AML / Financial Crime Technology & Cyber

Topics:

All Firms

🇪🇺 ESMA Consultation low

April 30th 2026

ESMA launches its sixth stress test exercise for Central Counterparties

ESMA launches its sixth stress test exercise for Central Counterparties 30 April 2026 CCP Press Releases The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, today launched its sixth stress test exercise for Central Counterparties (CCPs) . The CCP stress test framework drafted by ESMA for the purpose of this exercise is supported by an adverse market scenario provided by the European Systemic Risk Board (ESRB). Mandated under the European ...

Sectors:

AML / Financial Crime Prudential / Capital Requirements Technology & Cyber

Topics:

All Firms

Banking & Credit Investment Management Capital Markets & Trading Payments & E-Money Crypto & Digital Assets

🇮🇪 CBI Enforcement critical

April 29th 2026

Remarks by Director of Horizontal Supervision, Patricia Dunne to the European Anti-Financial Crime Summit, Dublin

Safeguarding Financial Integrity – Central Bank of Ireland’s Approach to Financial Crime Prevention Thank you for the invitation to speak at today’s event. This is an important opportunity for us to engage and share our experiences and approaches to deal with the global challenges and issues we are facing in financial crime. Change, instability, flux, unpredictability - all words that I guarantee you will hear on multiple occasions throughout the day’s events. I will not be any different. We ...

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Operational Resilience / Outsourcing

Bank

🇬🇧 FCA Speech

April 28th 2026

Trust, tradition and the future of mutual growth

Speech by Sarah Pritchard, FCA deputy chief executive, at the BSA Annual Conference, Edinburgh. As a history lover, it’s thrilling to be in a city like Edinburgh – called a ‘hot-bed of genius’ during the Scottish Enlightenment.What defined the Enlightenment spirit was the refusal to settle, and a determination to make things better for the future.It’s the kind of approach I’m taking to this moment of regulatory reform.Working with others to solve difficult problems, protecting trust and good ...

Sectors:

AML / Financial Crime Consumer Protection / Conduct Technology & Cyber

Topics:

Crypto Exchange

🇬🇧 FCA News

April 28th 2026

FCA invites ESG rating providers to join a voluntary reporting pilot

Help us develop a proportionate reporting regime for ESG ratings. Register your interest by 13 May 2026. We're inviting ESG rating providers to join a pilot to inform future regulatory reporting once the regime is live.Our aim is to avoid unnecessary reporting burden for firms over time.The pilot aims to help us assess whether the proposed metrics for ESG ratings reporting are:clearfeasibleproportionate across different business modelsuseful for supervisory purposesParticipants will have a di...

Deadline: 13 May 2026

Sectors:

AML / Financial Crime ESG Technology & Cyber

Topics:

All Firms

Banking & Credit Capital Markets & Trading Payments & E-Money Mortgage & Lending

🇮🇪 CBI Warning

April 28th 2026

Vigilance and Resilience - Strengthening Credit Unions in a Changing Landscape - Remarks by Domhnall Cullinan at ILCU Annual Conference

Good morning. Brendan, thank you for the warm introduction. It is a pleasure to join you at the ILCU Internal Audit Services Conference. I also want to thank Barry Harrington for the invitation to address you here today. 1 When I addressed the ILCU Annual Conference last April, I spoke about a time of transformative change for credit unions, a period that would bring both significant opportunities and important challenges. 2 One year on, we can see that transformation taking shape. A revised ...

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Prudential / Capital Requirements

All Firms

Banking & Credit Insurance & Pensions Capital Markets & Trading

🇪🇺 ESMA News

April 24th 2026

Joint Committee annual report highlights digitalisation, cyber resilience and sustainable finance as key priorities of 2025

Joint Committee annual report highlights digitalisation, cyber resilience and sustainable finance as key priorities of 2025 24 April 2026 Joint Committee The Joint Committee of the European Supervisory Authorities (EBA, EIOPA and ESMA – the ESAs) today published its Annual Report for 2025 , setting out the main priorities and achievements of its cross-sectoral work over the past year. In 2025, the Joint Committee focused on protecting consumers in increasingly digital financial markets, stren...

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Operational Resilience / Outsourcing

Fintech

Banking & Credit Capital Markets & Trading

🇬🇧 FCA News

April 24th 2026

FCA spearheads global action to stop illegal finfluencers

The FCA has led international action to stop illegal finfluencers putting consumers' money at risk. Seventeen regulators worldwide took part in the 'week of action' which included enforcement activity, consumer awareness campaigns, and educational programmes for finfluencers who want to act responsibly. Activity started on 20 April 2026.In the UK, the FCA:Secured a guilty plea from Geordie Shore’s Aaron Chalmers for illegal promotions on social media. Criminal proceedings have been commenced ...

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Prudential / Capital Requirements

All Firms

Banking & Credit Capital Markets & Trading Payments & E-Money

🇬🇧 FCA News

April 23rd 2026

Sapia agrees to pay more than £19m to WealthTek clients after failing to protect client money

Sapia has agreed to make a voluntary payment of £19,637,950 to WealthTek clients and the FCA has censured the firm. Sapia began working with WealthTek in 2013 and later appointed it as one of its appointed representatives. This resulted in Sapia holding and being responsible for protecting client money resulting from WealthTek’s activities.The FCA found Sapia did not put enough safeguards in place to protect this money.Sapia has admitted that it failed to properly separate key roles within it...

Sectors:

Topics:

AML / Financial Crime Technology & Cyber Market Abuse / Surveillance

Wealth ManagerFintech

Wealth & Private Banking Capital Markets & Trading

🇬🇧 FCA News

April 23rd 2026

FCA looks for members for its advisory committee on secondary markets

The FCA is looking for expressions of interest from market participants to join our advisory committee. The committee was established in 2022, and we are renewing the membership in line with our terms of reference.The purpose of the committee is to support our work in wholesale secondary markets for equities, derivatives, fixed income and commodity derivatives.The committee’s task is to:help develop reforms that improve market competition, increase consumer protection and enhance the integrit...

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Technology & Cyber

All Firms

Capital Markets & Trading Crypto & Digital Assets

🇬🇧 FCA News

April 22nd 2026

FCA and PRA confirm changes to streamline senior manager accountability and boost growth

Firms willbenefitfromreduced costs andgreater flexibility, andfind it easier tocomply with the Senior Managers and Certification Regime (SM&CR),following reformsset outon 22 April by theFCA and Prudential Regulation Authority (PRA). The changes, which come as the first phase of a multi-stage package of reform from the Government and regulators, will maintain the core principle of senior leader accountability, and will benefit firms by:Giving more time to submit senior manager applications whe...

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Prudential / Capital Requirements

All Firms

Capital Markets & Trading Crypto & Digital Assets

🇬🇧 FCA News

April 22nd 2026

FCA leads first crackdown on illegal crypto trading

The FCA has carried out its first operation with partners to disrupt illegal peer-to-peer crypto trading across multiple London locations. Working with HM Revenue & Customs (HMRC) and the South West Regional Organised Crime Unit (SWROCU), the FCA targeted 8 premises suspected of illegal peer-to-peer crypto trading. The FCA issued cease and desist letters at each site, notifying traders to stop illegal activity immediately. Evidence obtained during the on-site inspections is supporting a numbe...

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Technology & Cyber

Broker DealerCrypto Exchange

🇬🇧 BoE News

April 22nd 2026

FCA and PRA confirm changes to streamline senior manager accountability and boost growth

The PRA and FCA have set out reforms to the Senior Managers and Certification Regime, designed to reduce costs and offer greater flexibility.

Sectors:

AML / Financial Crime Technology & Cyber Senior Managers / Governance

Topics:

All Firms

Banking & Credit Capital Markets & Trading Payments & E-Money

🇬🇧 FCA News

April 21st 2026

FCA announces second cohort for AI Live Testing

Speaking at UK FinTech Week, Jessica Rusu, chief data, information and intelligence officer at the FCA, has confirmed the second group of firms selected to join AI Live Testing. Eight new firms, including Barclays, Experian, Lloyds Banking Group (Scottish Widows), and UBS, have been chosen by the FCA to live test AI applications to support safe and responsible deployment.The FCA is working with its technical partner Advai, a London-based specialist in automated AI assurance, to provide AI Liv...

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Technology & Cyber

BankFintech

Banking & Credit Investment Management Capital Markets & Trading

🇦🇪 ADGM News medium

April 20th 2026

20 Apr 2026 Read more

Sectors:

Topics:

AML / Financial Crime Prudential / Capital Requirements Technology & Cyber

BankAsset ManagerBroker Dealer

Banking & Credit Investment Management Payments & E-Money

🇱🇺 CSSF Consultation high

April 17th 2026

Public consultation by AMLA on the draft RTS on group-wide minimum requirements and additional measures for subsidiaries and branches in third countries

No description available.

AI Analysis

The CSSF publication highlights AMLA's public consultation on draft Regulatory Technical Standards (RTS) under Articles 16(4) and 17(3) of Regulation (EU) 2024/1624, specifying minimum group-wide AML/CFT requirements and additional measures for subsidiaries and branches in third countries. This matters because it aims to harmonize cross-border AML frameworks, ensuring groups maintain consolidated ML/TF risk views and robust controls, particularly in high-risk third-country operations, impacting EU financial groups' compliance structures. Private sector input is encouraged to align standards with practical operations.[https://www.cssf.lu/en/Document/public-consultation-by-amla-on-the-draft-rts-on-group-wide-minimum-requirements-and-additional-measures-for-subsidiaries-and-branches-in-third-countries/][https://www.amla.europa.eu/amla-consults-group-wide-requirements-and-business-wide-risk-assessment_en]

What Changed

- Group-wide AML/CFT frameworks: Establishes minimum standards for design and implementation across groups, including cross-border structures and third-country operations, to enable consolidated...
Third-country subsidiaries and branches: Introduces additional measures for entities in non-EU countries, extending requirements beyond traditional groups to other...
Information sharing and parent identification: Defines provisions for intra-group data sharing and criteria to identify the EU parent undertaking when multiple entities report to a third-country head...
Interlinked mandates: Cross-references obligations between Articles 16(4) and 17(3) for complementary requirements on organizational...

Suggested Considerations

Register for 20 May 2026 public hearing to engage directly on practical application across group structures.[https://www.amla.europa.eu/events/public-hearing-draft-rts-group-wide-minimum-requirements-and-additional-measures-subsidiaries-and-2026-05-20_en]
Assess current group-wide AML/CFT frameworks against proposed minimums, identifying gaps in third-country controls, risk consolidation, and data sharing protocols.

Compliance Impact

Urgency: High – Firms with third-country exposure must act now on consultation (closes 15 July 2026) to influence final RTS, as these will mandate binding minimums for group-wide AML/CFT, potentially requiring significant framework overhauls for risk consolidation and controls. Non-engagement risks misaligned systems post-adoption, increasing supervisory scrutiny under harmonized EU standards; early assessment prevents rushed...

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

Topics:

AML / Financial Crime Reporting & Disclosure Senior Managers / Governance

BankAsset ManagerPayment Provider

🇱🇺 CSSF Consultation high

April 17th 2026

Public consultation by AMLA on the draft Guidelines on business-wide risk assessment

No description available.

AI Analysis

AMLA has launched a public consultation on draft Guidelines for business-wide risk assessments (BWRA) under the new Anti-Money Laundering Regulation (EU 2024/1624), with submissions open until 15 July 2026. These guidelines establish minimum requirements for all obliged entities across financial and non-financial sectors to systematically identify and manage money laundering and terrorist financing risks inherent to their operations.

What Changed

The draft Guidelines introduce four minimum requirements for conducting adequate business-wide risk assessments applicable to all obliged entities. The framework mandates that entities:
Identify risk exposure across their business model, customers, products, services, transactions, delivery channels, and geographical exposure
Maintain consolidated risk views across group structures, eliminating silos between branches and subsidiaries
Utilize internal and external data sources to build comprehensive risk landscapes, including monitoring customer behavior changes and tracking international typologies
Apply proportionality based on entity size, business model, and risk profile, while ensuring consistent application of policies across the organization The guidelines specifically address evaluation...

Suggested Considerations

*Immediate (by 15 July 2026):
Review draft Guidelines and assess alignment with current BWRA practices
Identify gaps between existing risk assessment frameworks and proposed minimum requirements
Prepare formal consultation responses, particularly if your organization operates in non-financial sectors
Register for relevant public hearings (28 May for BWRA Guidelines; 20 May for group-wide RTS) to engage directly with AMLA

Key Dates

Later in 2026

- Final adoption of guidelines and technical standards

16 April 2026

Warning: Unauthorised Investment Firm / Unauthorised Investment Business Firm / Unauthorised Irish Collective Asset-Management Vehicle (ICAV) Unauthorised Firm Name Clarus IV ICAV (CLONE) Website https://www.clarusiv.com/ Email addresses used enquiries@clarusiv.com accounts@clarusiv.com michael.granger@clarusiv.com Phone number used +353 1525 9660 Authorisation in Ireland Clarus IV ICAV (Clone) is not authorised to provide investment services in Ireland. Additional Information This firm clone...

AI Analysis

The Central Bank of Ireland (CBI) has issued a warning notice under section 53 of the Central Bank (Supervision and Enforcement) Act 2013 regarding **Clarus IV ICAV (CLONE)**, an unauthorised entity cloning a legitimate authorised ICAV to perpetrate investment scams. This matters for compliance professionals as it underscores rising clone firm risks in Ireland's investment sector, requiring vigilance to protect clients and avoid facilitation of scams.

AI-generated analysis. May contain errors or omissions — verify with the original CBI source before acting. Full disclaimer.

Sectors:

Authorisation & Licensing Consumer Protection / Conduct AML / Financial Crime

Topics:

Asset ManagerAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇱🇺 CSSF News low

April 17th 2026

CSSF Newsletter No 303 – April 2026

No description available.

Sectors:

Topics:

AML / Financial Crime Prudential / Capital Requirements Reporting & Disclosure

BankAsset ManagerWealth Manager

Banking & Credit Investment Management Wealth & Private Banking

🇨🇭 FINMA News medium

April 17th 2026

Aktualisierte Sanktionsmeldung: Taliban

Das Staatssekretariat für Wirtschaft (SECO) hat eine Änderung der Liste der sanktionierten natürlichen Personen, Unternehmen und Organisationen der Verordnung vom 21. März 2025 über Massnahmen gegenüber Personen und Organisationen, die mit den Taliban in Verbindung stehen (SR 946.231.07), publiziert.

Sectors:

Topics:

AML / Financial Crime Prudential / Capital Requirements Reporting & Disclosure

BankWealth ManagerAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇱🇺 CSSF Warning high

April 17th 2026

Warning concerning the website www.werdy.net

No description available.

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Authorisation & Licensing

BankWealth ManagerFintech

Banking & Credit Investment Management Wealth & Private Banking

🇨🇭 FINMA News medium

April 16th 2026

Aktualisierte Sanktionsmeldung: Taliban

Das Staatssekretariat für Wirtschaft (SECO) hat eine Änderung der Liste der sanktionierten natürlichen Personen, Unternehmen und Organisationen der Verordnung vom 21. März 2025 über Massnahmen gegenüber Personen und Organisationen, die mit den Taliban in Verbindung stehen (SR 946.231.07), publiziert.

Sectors:

Topics:

AML / Financial Crime Prudential / Capital Requirements Reporting & Disclosure

BankWealth ManagerAll Firms

Banking & Credit Investment Management Capital Markets & Trading

🇺🇸 CFTC News high

April 15th 2026

CFTC Secures Court Order Requiring Florida Resident to Pay Over $1.3 Million in Disgorgement and Imposes Trading Ban for Commodity Pool Fraud

No description available.

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Authorisation & Licensing

BankBroker DealerAsset Manager

Crypto & Digital Assets Payments & E-Money

🇱🇺 CSSF Warning high

April 15th 2026

Warning concerning fraudulent activities by persons misusing the name of Coinbase Luxembourg S.A.

No description available.

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Authorisation & Licensing

Crypto ExchangeFintechPayment Provider

Banking & Credit Investment Management Wealth & Private Banking

🇨🇭 FINMA Enforcement high

April 14th 2026

Aktualisierte Sanktionsmeldung: Islamische Republik Iran

Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung der Anhänge 12 und 14 der Verordnung vom 12. Dezember 2025 über Massnahmen gegenüber der Islamischen Republik Iran (SR 946.231.143.6) publiziert.

AI Analysis

This FINMA publication announces updates to Annexes 12 and 14 of the Swiss Ordinance on Measures against the Islamic Republic of Iran (SR 946.231.143.6), effective April 14, 2026, reflecting changes to the SECO Sanctions Management (SESAM) database by the State Secretariat for Economic Affairs (SECO). It matters because Swiss financial intermediaries must immediately freeze assets of newly or amended sanctioned entities and report to SECO, while continuing AML due diligence under the Anti-Money Laundering Act (GwG), to avoid supervisory enforcement.[User Query]

What Changed

- Amendments to Annexes 12 and 14 of the Ordinance SR 946.231.143.6, updating the list of sanctioned persons, companies, and organizations in the context of Iran sanctions.[User Query]
Updates propagated to the SESAM database, published on the WBF/SECO website.[User Query]
Standard requirements reiterated: Implement prohibitions, freeze assets of sanctioned parties, and report affected business relationships to SECO; SECO reporting does not exempt additional GwG Art.

Suggested Considerations

Screen client portfolios, accounts, and transactions against the updated SESAM database and Annexes 12/14 immediately.
Freeze assets of any newly sanctioned or amended persons/entities without delay.
Report all affected business relationships to SECO promptly.
Conduct enhanced due diligence under GwG Art. 6 for any suspicion; if unresolved, file a suspicious activity report (SAR) with MROS under GwG Art. 9.
Monitor FINMA's MyFINMA portal and website for ongoing updates; update internal sanctions screening systems.[User Query]

Key Dates

13 April 2026

- WBF publishes changes to Annexes 12 and 14 and updates SESAM database.

14 April 2026, 23:00 UTC

- Changes enter into force; asset freezes and prohibitions become mandatory.

Compliance Impact

Urgency: High – Effective immediately (as of April 14, 2026, 23:00 UTC), non-compliance risks FINMA coercive measures under administrative law, including fines, supervisory proceedings, or license revocation. Matters due to frequent Iran sanctions updates (e.g., prior changes in March 2026, October 2025), heightened geopolitical risks post-2015 JCPOA unwind, and dual SECO/MROS reporting obligations amplifying AML exposure.[User Query]

References

AI-generated analysis. May contain errors or omissions — verify with the original FINMA source before acting. Full disclaimer.

Sectors:

Topics:

BankAsset ManagerWealth Manager

Banking & Credit Crypto & Digital Assets Payments & E-Money

🇦🇪 ADGM News high

April 14th 2026

Regulatory Alert Maskex

Sectors:

Topics:

AML / Financial Crime Authorisation & Licensing Consumer Protection / Conduct

Crypto ExchangeFintechPayment Provider

Consumer Credit Banking & Credit Mortgage & Lending

🇮🇪 CBI Enforcement medium

April 14th 2026

Finance Advice Help- Central Bank of Ireland Issues Warning on Unauthorised Firm

Warning: Unauthorised Retail Credit Firm Unauthorised Firm Name Finance Advice Help Website Financeadvicehelp.com Email address used contact@financeadvicehelp.com Authorisation in Ireland Finance Advice Help is not authorised to provide retail credit services in Ireland. Notes: Any person wishing to contact the Central Bank with information regarding such firms / persons may telephone (01) 224 5800 or report an unauthorised firm directly to the Central Bank . For more information on how to pr...

AI Analysis

The Central Bank of Ireland (CBI) has issued a warning notice under section 53 of the Central Bank (Supervision and Enforcement) Act 2013, identifying "Finance Advice Help" (website: financeadvicehelp.com; email: contact@financeadvicehelp.com) as an unauthorised firm providing retail credit services in Ireland. This matters for compliance professionals as it underscores CBI's proactive enforcement against unauthorised entities, heightening risks of consumer scams and potential liability for authorised firms if clients inadvertently engage with clones or similar frauds.[Source URL: https://www.centralbank.ie/news/article/finance-advice-help--central-bank-of-ireland-issues-warning-on-unauthorised-firm]

What Changed

This is not a regulatory change but an enforcement action via a public warning notice. It reinforces existing requirements under the Central Bank (Supervision and Enforcement) Act 2013 (section 53), which empowers CBI to publish names of unauthorised firms offering regulated services like retail credit. No new rules are introduced; it signals ongoing vigilance against unauthorised retail credit providers.[Source URL: https://www.centralbank.ie/news/article/finance-advice-help--central-bank-of-ireland-issues-warning-on-unauthorised-firm]

Suggested Considerations

Verify firm status: Use CBI's unauthorised firms search tool before engaging with any retail credit provider (https://www.centralbank.ie/regulation/how-we-regulate/authorisation/unauthorised-firms/search-unauthorised-firms).
Report suspicions: Contact CBI at (01) 224 5800 or via direct reporting portal for any dealings with Finance Advice Help or similar entities.[Source URL: https://www.centralbank.ie/news/article/finance-advice-help--central-bank-of-ireland-issues-warning-on-unauthorised-firm]
Educate clients/staff: Disseminate scam protection guidance from www.centralbank.ie/financialscams; implement "SAFE test" for verification.[Source URL: https://www.centralbank.ie/news/article/finance-advice-help--central-bank-of-ireland-issues-warning-on-unauthorised-firm]
Monitor clones: Screen for impersonation risks, as seen in related warnings (e.g., Shamrock Lend clone).

Key Dates

14 April 2026

Publication date of warning notice; Immediate public alert on unauthorised status of Finance Advice Help.[Source URL: https://www.centralbank.ie/news/article/finance-advice-help--central-bank-of-ireland-issues-warning-on-unauthorised-firm]

Compliance Impact

Urgency: Medium – This is a routine CBI warning (one of many in 2025-2026), not targeting authorised firms directly, but it elevates consumer protection and conduct risks. Firms must act promptly to update internal alerts and client advisories to mitigate reputational harm, regulatory scrutiny, or indirect liability from scam exposures; failure could trigger CBI inquiries under conduct rules.

References

AI-generated analysis. May contain errors or omissions — verify with the original CBI source before acting. Full disclaimer.

Sectors:

Topics:

Authorisation & Licensing Consumer Protection / Conduct AML / Financial Crime

BankFintechAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇮🇪 CBI Warning high

April 14th 2026

Fisher Investments Ireland Limited (CLONE) - Central Bank of Ireland Issues Warning on Unauthorised Firm

Sectors:

Topics:

Authorisation & Licensing Consumer Protection / Conduct AML / Financial Crime

BankWealth ManagerAsset Manager

Banking & Credit Wealth & Private Banking Crypto & Digital Assets

🇮🇪 CBI Warning high

April 14th 2026

Sanctions & settlements professional obligations Other professionals Journalists The AMF Enforcement Committee fines a financial investment advisor and its directors for breaches of their professional obligations

AI Analysis

The AMF Enforcement Committee sanctioned financial investment advisor Kerdiz Finance et Conseil with a €300,000 fine and its directors Anthony Finck and Marc Peuvrier with €75,000 fines each, plus a 5-year ban on advisory activities, for multiple breaches of professional obligations from 2020-2023. This case underscores AMF's strict enforcement against unauthorized product marketing, conflict of interest mismanagement, product governance failures, and AML shortcomings, serving as a warning for advisors to prioritize client best interests and regulatory compliance. It matters because it highlights personal liability for directors and escalating penalties for systemic procedural lapses.

What Changed

This is an enforcement decision, not a new regulation, but it reinforces existing AMF requirements under French financial advisor rules (e.g., derived from MiFID II and AIFMD implementations):
Accurate representation: Advisors must not misrepresent authorization status or claim unapproved services like investment services provision.[Source URL:...
Conflict of interest management: Procedures must identify and mitigate risks from commercial/ownership ties (e.g., to Vivat Multitalent group), beyond mere shareholding disclosures.
Product governance: Collect and review product information to ensure investor protection; verify asset managers/depositaries for securities.
Marketing limits: Prohibit advising prohibited securities (e.g., Multitalent AG bonds without French authorization) or high-risk offers like Guyane Agricole exceeding initial contributions.

Suggested Considerations

Immediate review: Audit marketing materials, website, and client communications for accurate authorization claims; cease any unapproved representations.
Enhance procedures: Update conflict of interest policies to fully identify/mitigate risks from promoter ties; implement robust product governance collecting issuer details (e.g., asset managers, depositaries, marketing eligibility in France).
Product due diligence: For all recommended securities/offers, verify French marketing authorization (e.g., AMF registration, prospectus, AIFMD passport); document high-risk features like loss exceeding contributions.
AML/CFT strengthening: Ensure full compliance with due diligence and inspector cooperation; conduct gap analysis against AMF guidelines.
Training and governance: Train directors/staff on personal liability; test procedures via internal audits.

Key Dates

What Changed

- Amendment to Annex 8 of SR 946.231.176.72 by the Federal Department for Economic Affairs, Education and Research (WBF) on March 19, 2026, removing 7 natural persons from the sanctions list.
Update to the official Swiss sanctions database SESAM (SECO Sanctions Management), published urgently on SECO's website.
This delisting narrows the scope of asset freeze obligations under the ordinance, but core prohibitions on transactions, asset blocking, and reporting for remaining listed parties persist.

Suggested Considerations

Screen client databases and transaction records against the updated SESAM database to identify and release any asset freezes or restrictions on the 7 delisted persons, confirming no residual sanctions apply.
Report any affected business relationships to SECO as per ordinance requirements; conduct additional due diligence under Art. 6 GwG if suspicions remain, and file SARs with the Money Laundering Reporting Office Switzerland (MROS) under Art. 9 GwG if unresolved.
Update internal sanctions screening tools, policies, and staff training to reflect the SESAM changes; document all reviews for audit trails.
Monitor FINMA's news and MyFINMA for further updates, as lists are continuously revised.

Key Dates

19 March 2026

- WBF amends Annex 8, removing 7 natural persons

20 March 2026, 23:00 UTC DEADLINE

- Changes enter into force; firms must adjust compliance systems accordingly

Compliance Impact

Urgency: High - Immediate action required post-20 March 2026 to avoid erroneous ongoing freezes (risking client claims) or premature releases (violating sanctions); non-compliance risks fines up to CHF 540,000 or imprisonment, with SECO referrals to prosecutors for severe cases, amid CHF 7.4 billion in frozen assets as of April 2025. This reinforces the need for real-time sanctions monitoring in a dynamic regime aligned with EU/UN measures.

References

AI-generated analysis. May contain errors or omissions — verify with the original FINMA source before acting. Full disclaimer.

Sectors:

Topics:

BankWealth ManagerAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇦🇪 ADGM News high

April 6th 2026

Sectors:

Topics:

AML / Financial Crime Prudential / Capital Requirements Authorisation & Licensing

BankWealth ManagerAsset Manager

Banking & Credit Investment Management Wealth & Private Banking

🇱🇺 CSSF News

April 2nd 2026

List of members of the CPDI (Updated)

No description available.

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Authorisation & Licensing

BankWealth ManagerAsset Manager

Crypto & Digital Assets Capital Markets & Trading

🇺🇸 CFTC News high

April 1st 2026

CFTC Resolves Action Against Former FTX Head of Engineering

No description available.

Sectors:

Topics:

AML / Financial Crime Authorisation & Licensing Reporting & Disclosure

Crypto ExchangeFintech

Banking & Credit Investment Management Crypto & Digital Assets

🇩🇪 BaFin News high

April 1st 2026

Calculus Investments Ltd.: BaFin warns consumers about offers on the website calculusinv(.)com and on social media channels promoting the sale and purchase of the CVUZ token via the “GVEXPRO” app

BaFin warns against offers on the website calculusinv(.)com and on social media channels such as the “Calculus Investment Academy VIP Y” group. According to information available to BaFin, Calculus Investments Ltd, which claims to be domiciled in New York and Frankfurt/Main, is providing financial, investment and cryptoasset services without the required authorisation.

Sectors:

Topics:

Consumer Protection / Conduct Authorisation & Licensing AML / Financial Crime

BankFintechCrypto Exchange

Banking & Credit Investment Management Wealth & Private Banking

🇨🇭 FINMA News high

April 1st 2026

Aktualisierte Sanktionsmeldung: ISIL (Da'esh) / Al-Kaida

Sectors:

Topics:

AML / Financial Crime Prudential / Capital Requirements Reporting & Disclosure

BankWealth ManagerAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇱🇺 CSSF News

April 1st 2026

Number of UCIs

Situation as at 28 February 2026

Sectors:

Topics:

AML / Financial Crime Prudential / Capital Requirements Reporting & Disclosure

BankAsset ManagerWealth Manager

Investment Management Capital Markets & Trading Wealth & Private Banking

🇸🇬 MAS Enforcement high

April 1st 2026

Key Enforcement Actions Taken by MAS in Q1 2026

The table below provides an overview of the key public enforcement actions taken by the Monetary Authority of Singapore (“MAS”) from January to March 2026.

AI Analysis

This MAS publication summarizes key public enforcement actions in Q1 2026, focusing on prohibition orders (POs) against individuals for investor fraud and money laundering, plus a joint operation against a licensed firm for AML failures and related offences. It matters as it underscores MAS's aggressive enforcement on financial crime, individual accountability, and firm controls, signaling heightened scrutiny to protect Singapore's financial centre integrity.[MAS publication]

What Changed

This is not a regulatory change document but a retrospective enforcement summary; no new requirements are imposed. It highlights MAS's ongoing application of existing powers under the Financial Services and Markets Act 2022 (FSMA), Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992 (CDSA), and related frameworks, emphasizing deterrence via POs, composition penalties, civil penalties, and criminal referrals.[MAS publication] Related context shows MAS reinforcing AML/CFT expectations, such as robust controls, senior management oversight, and escalation of...

Suggested Considerations

Conduct immediate AML/CFT control gap assessments, focusing on customer due diligence (CDD), transaction monitoring, source-of-funds verification, and suspicious transaction reporting (STR) timelines; integrate proliferation financing (PF) risks.
Enhance senior management oversight and accountability, ensuring compliance functions are resourced and independent; review director/representative conduct for fraud or ML risks.[MAS publication]
For CMS licensees and LFMCs: Update risk assessments for high-risk clients (e.g., trusts, beneficial ownership), automate quarterly reporting (e.g., QDC for mandates >SGD 500m), and train staff on accelerated STRs.
Perform thematic reviews of past flagged transactions and escalate unresolved suspicious activities to avoid composition penalties or POs.
All FIs: Prepare for heightened MAS inspections by documenting governance, including liquidity frameworks and cyber/AI risks tied to financial crime.

Compliance Impact

Urgency: High – This reinforces MAS's "evergreen" priorities on AML/CFT and market abuse, with rapid escalation to criminal probes, asset seizures, and long POs (up to 16 years), amid ongoing investigations like Capital Asia.[MAS publication] Firms risk supervisory actions, penalties (e.g., S$27.45m on FIs in 2025), and reputational damage, especially with 2026 priorities amplifying scrutiny on controls and reporting.

References

AI-generated analysis. May contain errors or omissions — verify with the original MAS source before acting. Full disclaimer.

Sectors:

Topics:

AML / Financial Crime Authorisation & Licensing Senior Managers / Governance

Asset ManagerWealth ManagerAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇦🇪 ADGM News

April 1st 2026

01 Apr 2026 Read more

Sectors:

Topics:

AML / Financial Crime Prudential / Capital Requirements Technology & Cyber

BankWealth ManagerFintech

AML / Financial Crime Prudential / Capital Requirements Reporting & Disclosure

🇺🇸 CFTC Enforcement high

March 31st 2026

NYU Law School Remarks – CFTC Enforcement Priorities, Insider Trading in the Prediction Markets, and Cooperation with the CFTC

No description available.

AI Analysis

This speech by CFTC Director of Enforcement David I. Miller outlines the Division's five core enforcement priorities for 2026—insider trading (especially in prediction markets), market manipulation, market abuse/disruptive trading, retail fraud, and willful AML/KYC violations—while announcing the end of "regulation by enforcement" and previewing a new cooperation policy with enhanced declination incentives. It matters because it signals a targeted, risk-based enforcement shift under Chairman Selig, emphasizing fraud detection over rulemaking, which demands immediate strengthening of surveillance, insider policies, and self-reporting in derivatives, crypto, and prediction markets. Firms face heightened scrutiny in these areas, with cooperation now explicitly tied to penalty mitigation.

What Changed

- End of "regulation by enforcement": CFTC Enforcement will focus solely on policing fraud, abuse, and manipulation under existing CEA anti-fraud provisions, avoiding policy-setting via enforcement...
Five explicit enforcement priorities: 1. Insider trading, with strong emphasis on prediction markets (e.g., misappropriation of nonpublic information violates CEA). 2.
New cooperation policy advisory (forthcoming soon): Includes "significant changes" to declination policy, building on prior frameworks like mitigation-credit matrices and safe harbors for...

Suggested Considerations

Enhance surveillance: Implement robust monitoring for insider trading in prediction markets, manipulation in energy, disruptive trading, retail fraud signals, and AML/KYC red flags; prioritize misappropriated nonpublic info detection.
Update policies: Revise insider trading protocols to align with CEA anti-fraud provisions; train staff on prediction market risks (debunking "no insider laws apply" myth).
Strengthen cooperation readiness: Develop self-reporting/escalation processes, remediation plans, and documentation for declination credit under forthcoming policy; review prior CFTC advisories (e.g., 2025 mitigation matrix).
Conduct gap analysis: Audit AML/KYC programs for willful violations; assess exposure in priority markets (energy, prediction/crypto, retail).
Monitor updates: Subscribe to CFTC Press Room for cooperation advisory and related actions (e.g., Feb 25, 2026 Prediction Markets Advisory post-enforcement cases: https://www.cftc.gov/PressRoom/PressReleases/9185-26).

Key Dates

BankWealth ManagerAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇮🇪 CBI Warning high

March 27th 2026

Naperte Designated Activity Company (CLONE) - Central Bank of Ireland issues warning about unauthorised firm

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Authorisation & Licensing

BankWealth ManagerAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇱🇺 CSSF News low

March 24th 2026

CSSF Newsletter No 302 – March 2026

No description available.

Sectors:

Topics:

AML / Financial Crime Prudential / Capital Requirements Reporting & Disclosure

BankAsset ManagerWealth Manager

Banking & Credit Wealth & Private Banking Payments & E-Money

🇨🇭 FINMA Enforcement medium

March 23rd 2026

Aktualisierte Sanktionsmeldung: Ukraine

AI Analysis

The Swiss Federal Department of Economic Affairs, Education and Research (WBF) amended Annex 8 of the Ordinance on Measures in Connection with the Situation in Ukraine (SR 946.231.176.72) on March 19, 2026, removing 7 natural persons from the sanctions list. This update requires financial intermediaries to immediately review and adjust their sanctions screening processes, as it directly impacts asset freeze obligations and reporting under Swiss sanctions regime.

What Changed

- Removal of 7 natural persons from Annex 8, which lists designated individuals subject to asset freezes and other restrictive measures related to the Ukraine situation.
Update to the SESAM sanctions database (SECO Sanctions Management), Switzerland's authoritative list aligned with EU sanctions.
No new designations or additional prohibitions introduced; this is a delisting that narrows the scope of sanctions application.

Suggested Considerations

Screen and release assets: Review client portfolios and frozen assets linked to the 7 delisted persons; release any previously frozen assets unless other sanctions apply (e.g., via GwG AML checks).
Update internal systems: Refresh sanctions screening tools with the latest SESAM data to avoid erroneous freezes or compliance breaches.
Report to SECO if applicable: If assets were frozen and are now releasable, notify SECO of prior relationships; conduct GwG Art. 6 due diligence and report suspicions to the Money Laundering Reporting Office (MROS) under Art. 9 GwG if unresolved.
Document changes: Maintain audit trails of screening adjustments to demonstrate compliance with ongoing supervisory obligations.

Key Dates

March 19, 2026

- WBF amends Annex 8 and publishes the update

March 20, 2026, 23:00 Uhr DEADLINE

- Changes enter into force; sanctions screening and asset handling must reflect delistings immediately thereafter

Compliance Impact

Urgency: Medium - The delisting reduces sanctions exposure but demands prompt action to unfreeze assets and update controls, as delays could lead to improper asset retention (potential liability) or missed opportunities for clients. Given the effective date was yesterday (March 20, 2026), firms must act today to align with FINMA expectations; non-compliance risks enforcement under administrative law.

References

AI-generated analysis. May contain errors or omissions — verify with the original FINMA source before acting. Full disclaimer.

Sectors:

Topics:

BankWealth ManagerPayment Provider

Banking & Credit Consumer Credit Mortgage & Lending

🇬🇧 FCA policy_statement high

March 20th 2026

FCA highlights risks when dealing with unregulated lenders

We are reminding regulated firms they need to undertake proper checks when dealing with unregulated lenders, safe custody providers, money brokers and financial leasing companies – also known as 'Annex 1' firms. There are around 1,200 of these firms registered with us for solely anti-money laundering purposes. Our powers are currently limited to looking at how these firms are meeting their anti-money laundering obligations and they are not subject to our wider rulebook. This regime is based o...

AI Analysis

The FCA statement reminds regulated firms to perform robust due diligence on 'Annex 1' firms—unregulated lenders, safe custody providers, money brokers, and financial leasing companies registered solely for AML purposes—due to their limited oversight and heightened financial crime risks. This matters because Annex 1 firms (approx. 1,200) are not subject to FCA's full rulebook, conduct rules, or protections like the Financial Ombudsman Service, exposing regulated firms to contagion risks if they fail to manage interactions properly. Non-compliance could lead to regulatory scrutiny, enforcement, or reputational damage amid FCA's ongoing AML focus.

What Changed

No new rules or legislative changes are introduced; this is a supervisory reminder reinforcing existing obligations under the Money Laundering Regulations 2017 (MLRs). It emphasizes enhanced due diligence on Annex 1 firms, referencing the 2025 National Risk Assessment (NRA) for risk management. The FCA highlights proactive engagement, including a 2024 letter to CEOs and follow-up with 300 firms in late 2025, signaling intensified supervision without altering the registration-only regime under the Financial Services and Markets Act.

Suggested Considerations

Verify Annex 1 registration status directly from the firm and via independent checks (e.g., FCA Register).
Understand the Annex 1 firm's business model, products, and risks, aligning with MLRs and 2025 NRA.
Manage identified risks, such as AML deficiencies or consumer encouragement into limited company structures for unregulated lending.
Document due diligence to demonstrate compliance, integrating into broader financial crime frameworks (e.g., BWRA/CRA per FCA findings).

Key Dates

2024

FCA letter to CEOs of Annex 1 firms raising AML concerns.; - **Late 2025 - FCA follow-up engagement with 300 Annex 1 firms.**

Compliance Impact

Urgency: High – This amplifies existing AML due diligence requirements amid FCA's 2025-30 financial crime strategy, with evidence of supervisory action (2024 letter, 2025 follow-ups). Failure risks enforcement, as Annex 1 interactions could facilitate financial crime or consumer harm without FOS protections; firms should audit exposures immediately to align with BWRA/CRA expectations and avoid findings like those in FCA's risk assessment review.

References

AI-generated analysis. May contain errors or omissions — verify with the original FCA source before acting. Full disclaimer.

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Authorisation & Licensing

BankPayment ProviderAll Firms

Banking & Credit Mortgage & Lending Investment Management

🇬🇧 FCA policy_statement critical

March 20th 2026

Investigation into Market Financial Solutions Limited

We have opened an enforcement investigation into Market Financial Solutions Limited (MFS). MFS is an Annex 1 business, which is solely registered with and supervised by us for its compliance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.Annex 1 registered firms are not authorised or subject to wider FCA regulation.MFS entered administration on 25 February 2026.

AI Analysis

The FCA has opened an enforcement investigation into Market Financial Solutions Limited (MFS) following the firm's entry into administration on 25 February 2026, amid allegations of serious financial irregularities, fraud, and double-pledging of collateral. This investigation is significant because it represents regulatory scrutiny of an Annex 1 business—a firm with limited FCA oversight—whose collapse exposed structural weaknesses in private credit markets and raised questions about due diligence practices across the financial sector.

AI-generated analysis. May contain errors or omissions — verify with the original FCA source before acting. Full disclaimer.

Sectors:

Topics:

AML / Financial Crime Authorisation & Licensing Senior Managers / Governance

BankAll Firms

Banking & Credit Investment Management Crypto & Digital Assets

🇩🇪 BaFin News high

March 20th 2026

Tradealles(.)com: BaFin warns consumers about website and identity fraud

The Federal Financial Supervisory Authority (BaFin) warns consumers about the services offered on the website tradealles(.)com. BaFin has information that this website is being used to offer financial, investment and cryptoasset services without the required authorisation.

Sectors:

Topics:

Consumer Protection / Conduct Authorisation & Licensing AML / Financial Crime

BankFintechCrypto Exchange

Banking & Credit Investment Management Wealth & Private Banking

🇩🇪 BaFin News high

March 20th 2026

Identity fraud: BaFin warns consumers about the website panthera-gmbh(.)com

The Federal Financial Supervisory Authority (BaFin) warns consumers about the services offered on the website panthera-gmbh(.)com. BaFin suspects the unknown operators of the website of offering consumers financial and investment services without the required authorisation.

Sectors:

Topics:

Consumer Protection / Conduct Authorisation & Licensing AML / Financial Crime

BankWealth ManagerFintech

Banking & Credit Investment Management Wealth & Private Banking

🇱🇺 CSSF Warning high

March 20th 2026

Warning concerning persons misusing the name of the Chair of the CSSF Board

(first publication: 30 October 2024)

Sectors:

Topics:

Consumer Protection / Conduct AML / Financial Crime Operational Resilience / Outsourcing

BankWealth ManagerAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇱🇺 CSSF News medium

March 19th 2026

Legal department - Consumer protection / financial crime (Updated)

Out-of-court consumer complaint resolution

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Operational Resilience / Outsourcing

BankWealth ManagerFintech

Investment Management Banking & Credit Wealth & Private Banking

🇱🇺 CSSF Warning high

March 18th 2026

Warning concerning fraudulent activities by persons misusing the name of JPMorgan Asset Management (Europe) S.à r.l.

No description available.

Sectors:

Topics:

Consumer Protection / Conduct AML / Financial Crime Authorisation & Licensing

Asset ManagerBankWealth Manager

Banking & Credit Investment Management Wealth & Private Banking

🇱🇺 CSSF Guidance high

March 18th 2026

Circular letter

Latest update on the AML/CFT standardised data collection

AI Analysis

This CSSF circular letter addresses the 2026 AML/CFT standardised data collection exercise, aligning with AMLA's EU-wide initiatives by adopting AMLA-developed templates for most supervised entities while requiring specialised professionals to use CSSF-specific forms. It matters for Luxembourg financial firms as it mandates reporting on ML/TF risks and mitigation measures to support consistent EU supervision, with recent delays emphasizing preparation needs amid evolving templates.

What Changed

- CSSF adopts AMLA-developed data collection templates for credit institutions, investment firms, and investment fund managers (excluding specialised professionals), replacing its prior questionnaire...
Entities selected for AMLA's mandatory calibration exercise (notified directly by CSSF) must report quantitative and qualitative ML/TF risk data; non-selected entities still report via AMLA templates...
Launch delayed from 2 March 2026 due to AMLA's consultation feedback on templates and guidance; new timelines and final questionnaire to be announced, but AMLA maintains 15 April 2026 submission for...
Specialised professionals of the financial sector complete a separate CSSF questionnaire, launching earlier on 23 February 2026 (subject to delay).

Suggested Considerations

Monitor CSSF communications for final questionnaire, launch dates, and eDesk access; prepare data on 2025 ML/TF risks and mitigation using current AMLA draft (not for submission).
Selected AMLA calibration participants: Compile and submit quantitative/qualitative data via eDesk by 15 April 2026; attend 13 March webinar.
Non-selected credit/financial institutions: Complete AMLA templates on ML/TF risks/mitigation for 2025 via eDesk upon launch.
Specialised professionals: Prepare CSSF-specific questionnaire ahead of (delayed) 23 February launch.
All: Ensure resources for timely reporting; review internal AML/CFT risk assessments for consistency with EU standards.

Key Dates

23 February 2026

- Planned launch for specialised professionals' CSSF questionnaire (delayed per 11 March update)

2 March 2026

Singapore, 17 March 2026 … The Monetary Authority of Singapore (MAS) has issued Prohibition Orders (POs) under the Financial Services and Markets Act 2022 (FSMA) against Mr Wang Qiming and Mr Liu Kai, former relationship managers, who were convicted of charges connected to the major money laundering case of August 2023. Given the gravity of their misconduct, MAS has issued a 16-year PO against Mr Wang Qiming and a 7-year PO against Mr Liu Kai.

AI Analysis

The Monetary Authority of Singapore (MAS) issued Prohibition Orders (POs) on 17 March 2026 under the Financial Services and Markets Act 2022 (FSMA) against former relationship managers Wang Qiming (16-year PO) and Liu Kai (7-year PO) for convictions tied to Singapore's S$3 billion money laundering scandal of August 2023. This enforcement action underscores MAS's rigorous application of fit and proper criteria, barring them from regulated activities due to forgery, money laundering, and related offences. It matters for compliance professionals as it signals heightened scrutiny on individual accountability in AML failures within wealth management.

What Changed

This is not a new regulation but an enforcement action applying existing FSMA powers. Key elements include:
MAS deeming individuals "not fit and proper" under Guidelines on Fit and Proper Criteria (section 7, FSMA), based on convictions for forgery (Penal Code), money laundering (Corruption, Drug...
POs prohibit: (i) carrying on MAS-regulated activities; (ii) direct/indirect management of financial institutions; (iii) acting as director/partner/manager of financial institutions; (iv)...
Durations reflect misconduct gravity: 16 years for Wang (four convictions, 24 months' jail, six taken into consideration); 7 years for Liu (one conviction, 4 months' jail). No broader regulatory...

Suggested Considerations

Screen existing/prospective staff: Immediately verify no employment of Wang/Liu or prior prohibited individuals (e.g., via MAS enforcement list); cease any roles if discovered.
Enhance RM onboarding/monitoring: Review KYC/CDD for HNWIs, especially from high-risk jurisdictions (e.g., Fujian-linked); audit forgery detection in documents.
Senior manager accountability: Ensure policies for AML audits, risk assessments; train on fit and proper obligations under FSMA Guidelines.
Report breaches: Disclose any inadvertent involvement to MAS promptly.
Firm-wide review: For scandal-linked FIs (e.g., 9 fined S$27.45m, 4 Blue Ocean staff POs), confirm remediation; others benchmark controls against MAS actions.

Key Dates

Topics:

AML / Financial Crime Consumer Protection / Conduct Prudential / Capital Requirements

BankWealth ManagerFintech

Banking & Credit Investment Management Wealth & Private Banking

🇨🇭 FINMA News medium

March 12th 2026

Aktualisierte Sanktionsmeldung: Taliban

Das Staatssekretariat für Wirtschaft (SECO) hat eine Änderung der Liste der sanktionierten natürlichen Personen, Unternehmen und Organisationen der Verordnung vom 21. März 2025 über Massnahmen gegenüber Personen und Gruppen, die mit den Taliban in Verbindung stehen (SR 946.231.07), publiziert.

Sectors:

Topics:

AML / Financial Crime Prudential / Capital Requirements Reporting & Disclosure

BankWealth ManagerAll Firms

Banking & Credit Investment Management Crypto & Digital Assets

🇩🇪 BaFin News high

March 12th 2026

VYNEX Trade: BaFin warns against offers in WhatsApp groups and against Lirunex Trading app

The Federal Financial Supervisory Authority BaFin warns against offers in WhatsApp groups, which are operated by alleged company VYNEX Trade. According to information available to BaFin, recommendations for the purchase of financial instruments and cryptocurrencies are offered in various WhatsApp groups, which can allegedly be traded via Lirunex Trading app and the following platforms:

Sectors:

Topics:

Consumer Protection / Conduct Authorisation & Licensing AML / Financial Crime

BankFintechCrypto Exchange

Banking & Credit Investment Management Wealth & Private Banking

🇱🇺 CSSF News medium

March 12th 2026

Interpretative note

Delay in the 2026 AML/CFT standardised data collection

Sectors:

Topics:

BankAsset ManagerWealth Manager

Banking & Credit Investment Management Wealth & Private Banking

🇱🇺 CSSF News medium

March 12th 2026

Reporting template

Delay in the 2026 AML/CFT standardised data collection

Sectors:

Topics:

BankAsset ManagerWealth Manager

Banking & Credit Investment Management Wealth & Private Banking

🇱🇺 CSSF News high

March 12th 2026

Public Hearings organised by AMLA on 24 March 2026

No description available.

Sectors:

Topics:

AML / Financial Crime Prudential / Capital Requirements Reporting & Disclosure

BankWealth ManagerAll Firms

Investment Management Capital Markets & Trading

🇭🇰 SFC News high

March 12th 2026

SFC and ICAC joint operation in alleged insider dealings and corruption involving senior executives of licensed corporations

No description available.

Sectors:

Topics:

AML / Financial Crime Market Abuse / Surveillance

Asset ManagerBroker DealerHedge Fund

Banking & Credit Investment Management Wealth & Private Banking

🇱🇺 CSSF Guidance medium

March 11th 2026

Circular letter

Delay in the 2026 AML/CFT standardised data collection

AI Analysis

The CSSF circular letter dated 11 March 2026 announces a delay in its planned AML/CFT standardised data collection exercise originally scheduled for 2026, primarily due to overlap with a concurrent broad-scope data collection by the European Anti-Money Laundering Authority (AMLA). This matters for compliance professionals as it reduces immediate reporting burdens on supervised entities, promotes regulatory simplification, and aligns Luxembourg practices with emerging EU AML/CFT methodologies, allowing firms to redirect resources to the mandatory AMLA exercise.

What Changed

- Postponement of CSSF-specific questionnaire: The CSSF has decided not to proceed with its own AML/CFT standardised data collection for most supervised entities (credit institutions, investment...
Exception for specialised professionals: Specialised professionals of the financial sector (e.g., certain non-credit institutions) remain subject to a CSSF-specific questionnaire, though timelines...
Rationale tied to AMLA calibration exercise: Entities selected for AMLA's 2026 calibration exercise (notified directly by CSSF) must complete it regardless; non-selected entities were to use AMLA...
Potential for ad-hoc requests: CSSF reserves the right to issue targeted questionnaires later in 2026 for essential data points not covered by AMLA. These changes supersede the 12 February 2026...

Suggested Considerations

Monitor CSSF updates: Await forthcoming communications on revised modalities, new timelines, and any ad-hoc requests via eDesk platform.
Prioritize AMLA obligations: Selected entities must prepare quantitative/qualitative ML/TF risk data per draft RTS on risk assessments (Article 40(2) of Directive (EU) 2024/1640); non-selected entities focus on AMLA templates for 2025 risks/mitigation.
Specialised professionals: Continue preparations for CSSF-specific questionnaire, confirming any shifts post-delay.
Internal review: Assess ML/TF risk profiles, mitigation measures, and reporting readiness in light of EU alignment; update compliance calendars to reflect simplification.
No immediate submissions: Stand down from original 2 March/15 April deadlines unless individually notified otherwise.

Key Dates

TBD 2026

Potential ad-hoc CSSF questionnaires for essential data points

23 February 2026

Original launch for specialised professionals' CSSF questionnaire

2 March 2026

Original launch date for AMLA calibration exercise data collection via eDesk (now potentially adjusted or paused per delay circular)

11 March 2026

Publication of delay circular, superseding prior timelines; further modalities to be communicated

15 April 2026 DEADLINE

Original reporting deadline to CSSF for AMLA calibration exercise data

Compliance Impact

Urgency: Medium. The delay alleviates short-term pressure by postponing submissions and reducing dual reporting, enabling resource reallocation to higher-priority AMLA efforts amid EU harmonization. It matters for maintaining a risk-based approach (RBA) under FATF standards, avoiding overburden from overlapping exercises, and preparing for the new EU AML/CFT methodology—non-compliance risks supervisory scrutiny, but the simplification lowers immediate enforcement exposure.

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

Topics:

BankAsset ManagerAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇦🇺 ASIC News low

March 11th 2026

Charges discontinued in Capital Mining Limited matter

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Reporting & Disclosure

BankWealth ManagerAsset Manager

Banking & Credit Investment Management Wealth & Private Banking

🇨🇭 FINMA Enforcement critical

March 10th 2026

Aktualisierte Sanktionsmeldung: Islamische Republik Iran

Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung der Anhänge 3, 12, 13 und 14 der Verordnung vom 12. Dezember 2025 über Massnahmen gegenüber der Islamischen Republik Iran (SR 946.231.143.6) publiziert.

AI Analysis

Switzerland's State Secretariat for Economic Affairs (WBF) has updated sanctions targeting the Islamic Republic of Iran, effective March 10, 2026 at 23:00 UTC, modifying annexes 3, 12, 13, and 14 of the Iran sanctions ordinance (SR 946.231.143.6). This represents a comprehensive revision of Iran-related financial restrictions that requires immediate compliance action from all Swiss financial intermediaries to freeze assets, implement prohibitions, and report affected business relationships.

What Changed

The regulatory update encompasses four substantive modifications:
Annex 3: Expansion of the goods list subject to export/import restrictions
Annexes 12, 13, and 14: Updates to the list of sanctioned persons, enterprises, and organizations subject to asset freezing and transaction prohibitions
SESAM Database: The Swiss sanctions management database (SECO Sanctions Management) has been updated to reflect all changes, published urgently on the WBF website The changes represent a total...

Suggested Considerations

*Implement Prohibitions: Execute all transaction bans and restrictions specified in the updated ordinance annexes
*Asset Freezing: Immediately freeze all assets and funds of sanctioned persons, enterprises, and organizations identified in the updated SESAM database
*Mandatory Reporting to SECO: Report all affected business relationships to the State Secretariat for Economic Affairs within required timeframes
*Enhanced Due Diligence: Conduct additional investigations under Article 6 of the Anti-Money Laundering Act (GwG) when suspicious indicators arise
*Suspicious Activity Reporting: If enhanced due diligence cannot eliminate suspicions, file mandatory reports with the Money Laundering Reporting Office (Meldestelle für Geldwäscherei) under Article 9 GwG without delay

Key Dates

Topics:

AML / Financial Crime Consumer Protection / Conduct Authorisation & Licensing

Wealth Manager

Investment Management Banking & Credit Capital Markets & Trading

🇸🇬 MAS News high

March 9th 2026

Licensed Fund Management Company And Its Officers Investigated For Suspected Money Laundering And Suspected Failure To Comply With Obligations As A Licensed Capital Markets Services Licence Holder

The Police and MAS jointly conducted enforcement operations against Capital Asia Investments Pte Ltd and its directors for suspected money laundering offences under Section 54 of the Corruption, Drug Trafficking and Other Serious Crimes (Confiscation of Benefits) Act 1992, and suspected failure to comply with various obligations as a licensed capital markets services licence holder under the Financial Services and Markets Act 2022.

Sectors:

Topics:

AML / Financial Crime Authorisation & Licensing Prudential / Capital Requirements

Asset ManagerBankBroker Dealer

Banking & Credit Investment Management Wealth & Private Banking

🇦🇺 ASIC News high

March 6th 2026

Federal Court finds two Star Entertainment senior executives breached duties, non-executive directors did not breach duties

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Senior Managers / Governance

BankWealth ManagerAll Firms

Investment Management Wealth & Private Banking Capital Markets & Trading

🇦🇺 ASIC News high

March 6th 2026

Administrative sanction imposed on an investment firm

AI Analysis

The CSSF imposed an administrative sanction on 8 October 2025 against an unnamed investment firm, as detailed in a publication released on 4 March 2026. This enforcement action underscores CSSF's rigorous oversight of investment firms, particularly in areas like AML/CFT compliance, conduct rules, and organizational requirements, serving as a warning for similar entities to strengthen cooperation and internal controls. It matters because it highlights escalating fines for repeated or material breaches, potentially influencing supervisory expectations across Luxembourg's financial sector.

What Changed

No new regulatory changes or requirements are introduced; this is an enforcement action applying existing rules.
Failure to cooperate with CSSF requests, e.g., not submitting required AML/CFT questionnaires by deadlines, violating Article 5(1) of the amended Law of 12 November 2004 on AML/CFT.
Non-compliance with investment policies, organizational requirements, or conduct rules under the UCI Law (e.g., Articles 41, 43, 109), including improper broker exposures or valuation failures.
These reflect ongoing enforcement of established frameworks like the AIFM Law, UCI Law, and AML/CFT Law, with fines calibrated by factors like breach duration, firm size, cooperation level, and prior...

Suggested Considerations

Enhance cooperation protocols: Implement automated tracking for CSSF requests (e.g., questionnaires) with escalations for reminders; document all responses.
Review investment compliance: Audit broker exposures, valuation processes, and subscription/redemption controls against UCI Law Articles 41-43, 109; suspend dealings if uncertainties arise.
Strengthen governance: Conduct gap analyses on internal controls, risk assessments, and reporting for depositary/oversight functions per AIFM Law Article 19(9) and CDR 231/2013.
Training and monitoring: Roll out firm-wide training on AML/CFT obligations (Article 5(1)) and perform reconciliations of assets/records; prepare for on-site/off-site CSSF inspections.
Self-reporting: Proactively disclose prior breaches to mitigate fine severity.

Key Dates

10 January 2025

- Date of prior depositary oversight fine

4 April 2025 DEADLINE

- Deadline for submitting CSSF AML/CFT Questionnaire (breach example from similar case)

16 July 2025

- Date of fine imposition for UCITS investment policy breaches

11 September 2025

- Date of fine imposition in comparable AIFM non-cooperation case

8 October 2025

- Date of the sanction in question

Compliance Impact

Urgency: High - This matters due to CSSF's pattern of publicizing nominative sanctions (e.g., Max Gain Capital, Zeus Asset Management), signaling increased scrutiny on investment firms amid AML/CFT and conduct risks. Fines (EUR 10,000–127,500) represent material hits (up to 10% of turnover), with factors like poor cooperation amplifying penalties; firms with similar exposures face elevated inspection risk, especially post-2025 enforcement wave.

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Senior Managers / Governance

Asset ManagerBroker DealerWealth Manager

Banking & Credit Investment Management Wealth & Private Banking

🇦🇪 ADGM News high

March 4th 2026

The latest report from the Office for Professional Body Anti-Money Laundering Supervision (OPBAS) finds there is still room for improvement. The anti-money laundering supervisors of professional services firms are more effective than at any time since 2018. However, OPBAS remains concerned that their enforcement lacks the teeth to deter firms from falling short of minimum standards.OPBAS’s latest report found Professional Body Supervisors (PBSs) generally continue to demonstrate good levels o...

Effective Date: 31 December 2018

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Prudential / Capital Requirements

BankWealth ManagerAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇱🇺 CSSF News high

March 3rd 2026

Council Implementing Regulation (EU) 2026/489 of 26 February 2026

implementing Regulation (EU) No 208/2014 concerning restrictive measures directed against certain persons, entities and bodies in view of the situation in Ukraine

Sectors:

Topics:

AML / Financial Crime Prudential / Capital Requirements Reporting & Disclosure

BankWealth ManagerAsset Manager

Banking & Credit Investment Management Wealth & Private Banking

🇱🇺 CSSF News high

March 3rd 2026

Council Implementing Regulation (EU) 2026/426 of 26 February 2026

implementing Article 8a of Regulation (EC) No 765/2006 concerning restrictive measures in view of the situation in Belarus and the involvement of Belarus in the Russian aggression against Ukraine

Sectors:

Topics:

AML / Financial Crime Prudential / Capital Requirements Reporting & Disclosure

BankWealth ManagerAsset Manager

Banking & Credit Investment Management Wealth & Private Banking

🇩🇪 BaFin News high

March 2nd 2026

Identity fraud: BaFin warns consumers about the website goldingfx(.)com

The Federal Financial Supervisory Authority (BaFin) warns consumers about the services offered on the website goldingfx(.)com. BaFin suspects the unknown operators of the website of offering consumers financial and investment services without the required authorisation. Contrary to the claims on the website, the services offered do not originate from Golding Capital Partners GmbH, which has its registered office in Munich. This is a case of identity fraud.

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Authorisation & Licensing

BankWealth ManagerFintech

Banking & Credit Capital Markets & Trading Crypto & Digital Assets

🇯🇵 JFSA News medium

March 2nd 2026

Press Conferences,Press Conference by KATAYAMA Satsuki, Minister of State for Financial Services (February 20, 2026)

No description available.

Sectors:

Topics:

AML / Financial Crime Market Abuse / Surveillance Reporting & Disclosure

BankBroker DealerCrypto Exchange

Banking & Credit Consumer Credit Mortgage & Lending

🇮🇪 CBI Warning high

March 2nd 2026

Stalwart Investments Limited (Clone) - Central Bank of Ireland Issues Warning on Unauthorised Firm

Sectors:

Topics:

Consumer Protection / Conduct Authorisation & Licensing AML / Financial Crime

BankFintechAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇦🇪 DFSA News high

March 2nd 2026

DFSA AML and Glossary Modules amendments come into force; FAQs published

Sectors:

Topics:

AML / Financial Crime Prudential / Capital Requirements Authorisation & Licensing

BankWealth ManagerAsset Manager

Banking & Credit Wealth & Private Banking

🇨🇭 FINMA News critical

February 27th 2026

FINMA proceedings: MBaer Merchant Bank AG in liquidation

In enforcement proceedings against MBaer Merchant Bank AG that FINMA concluded three weeks ago and which were recently pending before the Swiss Federal Administrative Court, FINMA had withdrawn the bank's licence. As part of the proceedings, FINMA ascertained that the bank does not have an adequate structure in place for combating money laundering, thus enabling clients to circumvent official asset freezes. The bank has now withdrawn its appeal against the FINMA proceedings, meaning that FINM...

Sectors:

Topics:

Bank

Banking & Credit Payments & E-Money Crypto & Digital Assets

🇸🇬 MAS News low

February 27th 2026

Der Bundesrat hat am 25. Februar 2026 beschlossen, die weiteren Massnahmen des 19. Sanktionspakets der Europäischen Union (EU) gegenüber Russland zu übernehmen. Die neuen Massnahmen treten am 26. Februar 2026 in Kraft.

AI Analysis

Switzerland's Federal Council adopted additional measures from the EU's 19th sanctions package against Russia and Belarus on February 25, 2026, effective immediately on February 26, 2026, expanding asset freezes to approximately 2,600 persons, entities, and organizations. This matters for Swiss financial intermediaries as it introduces new prohibitions on crypto services to Russian nationals and firms, transactions with ruble-pegged stablecoins like "A7A5", and extended bans on specialized messaging services for payments, alongside trade restrictions, requiring urgent asset screening and reporting to SECO.

What Changed

- Crypto Restrictions: Complete ban on providing any crypto services to Russian nationals and companies; prohibition on transactions involving specific ruble-backed crypto assets, such as the...
Payment Systems: Expansion of bans on using certain specialized messaging services for payment traffic.
Trade/Goods Bans: Expanded list of goods contributing to Russia's military/technological strengthening, including metals for weapon systems, fuel production products, and acyclic hydrocarbons (key...
Sanctions List Expansion: Builds on December 12, 2025 addition of 64 persons/organizations; Swiss list now aligns fully with EU's, covering ~2,600 targets subject to asset freezes related to Ukraine...
Related EU 19th package details (adopted by Switzerland) include sanctions on Rosneft/Gazprom Neft, shadow fleet ships, new banks, payment systems like Mir/SPFS, and import bans on LNG/acyclic...

Suggested Considerations

Implement all prohibitions immediately: Block crypto services to Russian nationals/companies; halt transactions with ruble-pegged stablecoins like A7A5; cease use of banned messaging services for payments.
Screen and freeze assets of sanctioned persons/entities (~2,600 total); report affected business relationships to SECO.
Conduct additional due diligence under Art. 6 GwG on suspicions; if unresolved, file immediate suspicious activity report to money laundering reporting office under Art. 9 GwG (SECO report does not exempt this).
Update sanctions screening tools, client onboarding, and transaction monitoring for new crypto/trade restrictions; review exposures to energy/finance goods listed.

Key Dates

12 December 2025

- Initial adoption of partial 19th package measures, adding 64 persons/organizations to Swiss sanctions list

13 December 2025

- Entry into force of December 2025 sanctions expansions (related prior update)

26 February 2026

- New measures from EU 19th sanctions package enter into force in Switzerland

Compliance Impact

Urgency: Critical - Effective today (26 February 2026), requiring immediate asset freezes, service halts, and SECO reporting to avoid violations punishable by fines up to CHF 540,000 or 5 years imprisonment (severe cases referred to federal prosecutor); GwG suspicions add AML reporting layers with CHF 100,000 fines for non-reporting. Crypto bans directly target growing evasion risks, amplifying exposure for digital asset firms amid Russia's war economy circumvention tactics.

References

AI-generated analysis. May contain errors or omissions — verify with the original FINMA source before acting. Full disclaimer.

Sectors:

Topics:

BankPayment ProviderCrypto Exchange

Banking & Credit Investment Management Wealth & Private Banking

🇨🇭 FINMA Enforcement high

February 26th 2026

Aktualisierte Sanktionsmeldung: Sudan

Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung des Anhangs der Verordnung vom 25. Mai 2025 über Massnahmen gegenüber Sudan (SR 946.231.18) publiziert.

AI Analysis

This FINMA publication announces an update to the Swiss sanctions list for Sudan following changes by the UN Sanctions Committee on February 24, 2026, directly incorporated into Switzerland's SESAM database by SECO on February 25, 2026. It matters because financial intermediaries must immediately freeze assets of newly listed parties and report to SECO, while continuing AML due diligence under the GwG (Anti-Money Laundering Act), to avoid enforcement risks from non-compliance with Embargo Act (EmbG) obligations.

What Changed

- The UN Sanctions Committee for Sudan amended its list of sanctioned natural persons, companies, and organizations on February 24, 2026.
SECO updated the SESAM (SECO Sanctions Management) database and published the changes on its website on February 25, 2026.
This triggers direct applicability in Switzerland under the Federal Council's 2016 ordinance for automatic adoption of UN sanctions lists, amending Annex of SR 946.231.18 (Ordinance on Measures...
Financial intermediaries are required to implement prohibitions, freeze assets, and report affected business relationships to SECO; SECO reporting does not exempt AML suspicions under Art.

Suggested Considerations

Screen client portfolios, accounts, and transactions against the updated SESAM Sudan list via SECO's website or MyFINMA notifications.
Freeze (block) assets of any matches and implement transaction prohibitions per the ordinance.
Report affected business relationships to SECO promptly.
Conduct additional due diligence under Art. 6 GwG for suspicions; if unresolved, file immediate suspicious activity report to the Money Laundering Reporting Office Switzerland (MROS) under Art. 9 GwG.
Monitor FINMA's sanctions page for ongoing updates: https://www.finma.ch/en/documentation/international-sanctions-and-combating-terrorism/international-sanctions-and-independent-freezing-measures/.

Key Dates

Topics:

AML / Financial Crime Prudential / Capital Requirements Reporting & Disclosure

BankWealth ManagerAsset Manager

Banking & Credit Investment Management Capital Markets & Trading

🇪🇺 ESMA Consultation high

February 25th 2026

The EBA and ESMA consult on revised suitability assessment requirements for banks and investment firms

The EBA and ESMA consult on revised suitability assessment requirements for banks and investment firms 25 February 2026 Investor protection The European Banking Authority (EBA) and the European Securities and Markets Authority (ESMA) today launched a consultation on the revised joint guidelines on the assessment of the suitability of members of the management body and key function holders . The revised guidelines form part of a broader package designed to harmonise suitability assessments and...

AI Analysis

The EBA and ESMA have launched a consultation on revised joint guidelines updating suitability assessments for management body members and key function holders in banks and investment firms, incorporating new requirements from the revised CRD and MiFID II to enhance harmonization and supervisory convergence. This matters for compliance professionals as it introduces mandatory assessments for additional roles, strengthens AML/CFT links, and includes simplifications to reduce burdens, potentially impacting governance processes once finalized and replacing the 2021 guidelines.

What Changed

- Incorporation of revised CRD requirements for large institutions, including ex-ante applications where authorities perform ex-post assessments, and mandatory suitability assessments for key roles...
Expanded application to CRD-covered entities and MiFID II investment firms, with further specifications for third-country branches.
Strengthened integration with AML/CFT framework, providing guidance on identifying reasonable grounds to suspect money laundering or terrorist financing risks during assessments.
Introduction of targeted simplifications to streamline processes, reduce administrative burdens, and offer greater flexibility/clarity for institutions and supervisors.
Parallel EBA consultation on RTS specifying standardized documentation (e.g., suitability questionnaires, CVs, internal assessments) for large institutions to ensure consistent submissions.

Suggested Considerations

Assess current suitability processes against new requirements (e.g., ex-ante applications, AML/CFT checks, third-country branch specs) and prepare for mandatory assessments of additional roles like CFOs.
For large institutions, evaluate EBA RTS on documentation and align internal templates (e.g., suitability questionnaires, CVs).
Participate in public hearings on 15 April 2026 if relevant.
Plan governance updates, including ongoing monitoring of collective/individual suitability and corrective measures.

Key Dates

15 April 2026, 14:00

15:30; - Public hearing on joint guidelines

15 April 2026, 15:30

16:30; - Public hearing on EBA RTS

25 May 2026 DEADLINE

- Deadline for submitting comments on joint guidelines and EBA RTS

Post

25 May 2026; - EBA publishes all contributions (unless requested otherwise)

TBD (post

consultation); - Revised guidelines enter into force, repealing 2021 guidelines

Compliance Impact

Urgency: High - As a consultation launched today (25 February 2026), firms have ~3 months to engage, but final guidelines will repeal existing ones, mandating process updates for core governance/AML functions in banks and investment firms; delays risk non-compliance with harmonized EU standards, especially for large institutions facing RTS on documentation. Matters due to expanded scope (e.g., CFOs, third-country branches) and AML ties, amplifying fit-and-proper regime enforcement amid supervisory convergence push.

References

AI-generated analysis. May contain errors or omissions — verify with the original ESMA source before acting. Full disclaimer.

Sectors:

Topics:

Senior Managers / Governance AML / Financial Crime Prudential / Capital Requirements

BankBroker DealerAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇱🇺 CSSF Warning high

February 25th 2026

Warning concerning the fraudulent activities carried out by Aisbierg Ennerstetzung Bank

No description available.

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Authorisation & Licensing

BankWealth Manager

Banking & Credit Investment Management Wealth & Private Banking

🇨🇭 FINMA Enforcement critical

February 25th 2026

Aktualisierte Sanktionsmeldung: Russland

Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat Änderungen des Anhangs 8 der Verordnung vom 4. März 2022 über Massnahmen im Zusammenhang mit der Situation in der Ukraine (SR 946.231.176.72) publiziert.

AI Analysis

On February 23, 2026, Switzerland's State Secretariat for Economic Affairs (SECO) updated Annex 8 of the Ukraine Sanctions Ordinance (SR 946.231.176.72), with changes taking effect on February 24, 2026 at 11:00 PM UTC. This represents the latest iteration of Switzerland's Russia sanctions regime, requiring financial intermediaries to immediately implement new prohibitions, freeze assets of designated persons, and report affected business relationships to SECO—with mandatory additional due diligence under anti-money laundering law if suspicions cannot be resolved.

What Changed

The February 2026 update to Annex 8 of the Ukraine Sanctions Ordinance introduces modifications to Switzerland's designated persons and entities list related to Russia sanctions.
22 natural persons and 42 companies/organizations subject to asset freezes and supply prohibitions
116 vessels (primarily tankers in Russia's shadow fleet circumventing oil price caps) subject to purchase, sale, and service prohibitions
45 companies in third countries subject to stricter export controls targeting critical goods for Russia's military-industrial complex
5 Russian banks and 4 foreign branches subject to transaction prohibitions due to use of Russian payment systems

Suggested Considerations

*Implement all prohibitions specified in updated Annex 8 across all business lines and customer relationships
*Freeze assets of all newly designated natural persons and entities; block transactions with designated entities
*Report to SECO all affected business relationships within required timeframes, documenting:
Customer identification and beneficial ownership
Transaction history with designated parties

Key Dates

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Authorisation & Licensing

BankWealth ManagerFintech

Banking & Credit Crypto & Digital Assets

🇩🇪 BaFin Warning high

February 23rd 2026

Identity Fraud: BaFin Warns About Offers On Website krf-mbh(.)com

The German Federal Financial Supervisory Authority (BaFin) has issued a warning regarding offers available at the website krf-mbh(.)com, purportedly operated by Gesellschaft für Kryptoregisterführung GmbH based in Willich. However, these offerings do not originate from Gesellschaft für Kryptoregisterführung GmbH nor any of their staff members; it's a clear instance of identity fraud. Unauthorized individuals are providing unauthorized financial and cryptocurrency-related services through this...

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Authorisation & Licensing

BankFintechCrypto Exchange

Banking & Credit Payments & E-Money Crypto & Digital Assets

🇩🇪 BaFin Warning high

February 20th 2026

Identity Fraud: BaFin warns of unfair job offer on the website vios-beratung(.)de

The financial supervisory authority BaFin is warning about a dubious job advertisement on the website vios-beratung(.)de which allegedly operates from the VIOS Consulting GmbH, Bielefeld. However, the offers on this site do not come from the VIOS Consulting GmbH or its employees. This is identity fraud. Unknown operators are advertising private individuals with seemingly lucrative job opportunities that involve opening accounts for testing purposes and transferring money or cryptocurrencies a...

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Authorisation & Licensing

BankFintechCrypto Exchange

Banking & Credit Investment Management Wealth & Private Banking

🇩🇪 BaFin News high

February 20th 2026

Tethys Investment Alliance: BaFin warns against offers in WhatsApp groups and indicates identity fraud at the expense of Tethys Investment Management LLC

The German Financial Supervisory Authority (BaFin) warns against the WhatsApp groups „Tethys Investment Alliance 771“ and „Tethys Investment Alliance-S62“, the websites „tethys-alliance.de“ and „tethys-uberblick.com“ as well as the apps „QVTCoinese“ und „QVTCoinese Pro“, which are allegedly operated by the Baku/Boston/Dubai-based company Tethys Investment Management LLC. In the WhatsApp groups consumers are enticed to trade financial products via the respective apps. It is suspected that the ...

Sectors:

Topics:

Consumer Protection / Conduct Authorisation & Licensing AML / Financial Crime

BankWealth ManagerFintech

Banking & Credit Investment Management Crypto & Digital Assets

🇩🇪 BaFin News high

February 19th 2026

Dukas-Global: BaFin warns consumers about the website dukas-global(.)com

The Federal Financial Supervisory Authority (BaFin) warns consumers about the company Dukas-Global and the services it is offering. BaFin suspects the unknown operators of the website dukas-global(.)com of offering consumers financial, investment and cryptoasset services without the required authorisation.

Sectors:

Topics:

Authorisation & Licensing Consumer Protection / Conduct AML / Financial Crime

BankFintechCrypto Exchange

Investment Management Crypto & Digital Assets Payments & E-Money

🇩🇪 BaFin News high

February 19th 2026

BaFin warns consumers about the website blue-invest(.)org

The Federal Financial Supervisory Authority (BaFin) warns consumers about the services offered on the website blue-invest(.)org. BaFin has information that the operators are offering banking business and/or financial services on this website without the required authorisation. The operators are not supervised by BaFin.

Sectors:

Topics:

Consumer Protection / Conduct Authorisation & Licensing AML / Financial Crime

FintechCrypto ExchangeAll Firms

Banking & Credit Investment Management Payments & E-Money

🇨🇭 FINMA Enforcement high

February 19th 2026

Aktualisierte Sanktionsmeldung: Sudan

Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung (WBF) hat den Anhang 2 der Verordnung vom 25. Mai 2005 über Massnahmen gegenüber Sudan (SR 946.231.18) geändert.

AI Analysis

The Swiss Federal Department for Economic Affairs, Education and Research (WBF) has amended Annex 2 of the Ordinance of 25 May 2005 on Measures against Sudan (SR 946.231.18), updating Switzerland's sanctions list in alignment with UN and international developments. This matters for Swiss financial institutions as it imposes immediate asset freeze and reporting obligations on newly designated individuals and entities linked to threats against Sudan's peace and security, including RSF support and mercenary activities. Compliance teams must screen and act swiftly to avoid FINMA enforcement under supervisory law.

What Changed

- Amendment to Annex 2 of SR 946.231.18 by WBF, adding seven individuals to the Sudan sanctions list, mirroring recent UN-aligned updates (e.g., UK additions on 5 February 2026 for persons like...
Sanctions include asset freezes, prohibitions on dealings with designated persons' funds or economic resources, and mandatory reporting to authorities, consistent with Switzerland's implementation of...
Updates reflect global coordination, with UNSC Resolution 2791 (2025) extending the Sudan regime to 12 October 2026, emphasizing targeted measures against human rights violations, humanitarian...

Suggested Considerations

Immediate screening: Review client databases, transactions, and assets against updated Annex 2 for the seven new designations; freeze any matching funds or resources without delay.
Reporting: Notify FINMA or relevant authorities (e.g., State Secretariat for Economic Affairs SECO) of any holdings or suspicions; relevant firms must report to OFSI equivalents in Switzerland.
No dealings: Cease all transactions, payments, or benefits to/from designated persons unless licensed; maintain records for 10+ years per Embargo Act.
Controls update: Enhance sanctions screening tools, train staff, and audit AML/sanctions programs for Sudan-specific risks like RSF financing or mercenaries.
Licensing check: Apply for exceptions via SECO if needed for humanitarian or existing obligations.

Key Dates

5 February 2026

- UK adds six individuals to Sudan sanctions list (e.g., SUD0026 to SUD0031), informing Swiss alignment

18 February 2026

1) high-risk jurisdictions on which enhanced due diligence and, where appropriate, counter-measures are imposed2) jurisdictions under increased monitoring of the FATFVersion of 17 February 2026

AI Analysis

The Annex of Circular CSSF 22/822 (Version of 17 February 2026) is Luxembourg's Commission de Surveillance du Secteur Financier's implementation guidance on FATF (Financial Action Task Force) designations of high-risk jurisdictions requiring enhanced due diligence and counter-measures, as well as jurisdictions under increased monitoring. This document is critical for Luxembourg-regulated financial institutions because it operationalizes international AML/CFT standards into binding compliance obligations, directly impacting customer acceptance, transaction monitoring, and correspondent banking relationships.

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

Topics:

BankAsset ManagerPayment Provider

Banking & Credit Investment Management Wealth & Private Banking

🇩🇪 BaFin Speech high

February 18th 2026

Identity theft: BaFin warns against offers from the email address info[at]lgimeu(.)com

The Federal Financial Supervisory Authority BaFin warns against fixed-term deposit offers sent from the email address info[at]lgimeu(.)com. According to information available to BaFin, the unknown providers are conducting banking transactions without the required authorisation. The offers do not originate from LGIM Managers (Europe) Limited. This is a case of identity theft.

Sectors:

Topics:

Consumer Protection / Conduct Authorisation & Licensing AML / Financial Crime

BankAsset ManagerWealth Manager

Investment Management Crypto & Digital Assets Capital Markets & Trading

🇫🇷 AMF Consultation high

February 17th 2026

The AMF invites financial market participants to AMLA’s consultations on three draft AML/CFT implementing standards

Anti-money Laundering Asset management The AMF invites financial market participants to AMLA’s consultations on three draft AML/CFT implementing standards

AI Analysis

The AMF is urging financial market participants, especially in asset management and related sectors, to engage in AMLA's public consultations on three draft Regulatory Technical Standards (RTS) under the new EU AML/CFT package, covering customer due diligence (CDD), identification of business relationships/transactions, and enforcement measures. These RTS aim to provide harmonized, proportionate implementation guidance, significantly impacting CDD processes and supervisory consistency across the EU, with underlying rules applying from 10 July 2027.[Source URL: https://www.amf-france.org/en/news-publications/news/amf-invites-financial-market-participants-amlas-consultations-three-draft-amlcft-implementing#xts=607212&xtor=RSS-11&type=RSS]

What Changed

- CDD RTS: Builds on EBA's prior draft with AMLA refinements for legal clarity, proportionality, and risk adaptation; specifies information/sources for identity verification of natural persons/legal...
Business Relationships/Occasional/Linked Transactions RTS: Defines criteria under AMLR Article 19(9) to harmonize identification, ensuring consistent EU-wide application beyond basic...
Enforcement RTS (Pecuniary Sanctions/Administrative Measures): Under AMLD6 Article 53(10), standardizes supervisor assessment/categorization of breaches for proportionate, effective, dissuasive...

Suggested Considerations

Gap analysis and preparation: Assess current CDD/business identification/enforcement processes against drafts; identify changes for remote onboarding, PEPs, sectoral measures (e.g., asset manager Article 17 scenarios), and sanctions screening; set milestones for policy/system updates by July 2027.
Engage hearings: Attend 24 March 2026 public hearing for CDD/business RTS.
Monitor post-consultation: Track AMLA/EC adoption (expected Q1 2026 for some related RTS) and national implementations (e.g., CSSF data reporting).

Key Dates

9 February 2026

- Consultations opened by AMLA on three draft RTS.[Source URL: https://www.amf-france.org/en/news-publications/news/amf-invites-financial-market-participants-amlas-consultations-three-draft-amlcft-implementing#xts=607212&xtor=RSS-11&type=RSS]

9 March 2026

- Consultation closes on RTS for pecuniary sanctions/administrative measures

24 March 2026

- Online public hearing on CDD and business relationships RTS

8 May 2026

- Consultations close on CDD RTS and business relationships/linked transactions RTS.[Source URL: https://www.amf-france.org/en/news-publications/news/amf-invites-financial-market-participants-amlas-consultations-three-draft-amlcft-implementing#xts=607212&xtor=RSS-11&type=RSS]

10 July 2026

- AMLA submits final draft RTS to European Commission for adoption

Compliance Impact

Urgency: High - These RTS operationalize core AMLR/AMLD6 mandates with July 2027 applicability, demanding immediate consultation input to influence final rules and 18-month lead time for system/process overhauls (e.g., CDD verification sources, harmonized transaction linking). Failure to engage risks non-compliant frameworks amid AMLA's push for EU-wide consistency, elevated direct supervision risks, and stricter enforcement; asset managers face acute challenges from intermediary distribution rules.[Source URL:...

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

Topics:

AML / Financial Crime Reporting & Disclosure Authorisation & Licensing

Asset ManagerCrypto ExchangeAll Firms

Investment Management Crypto & Digital Assets Wealth & Private Banking

🇱🇺 CSSF Guidance high

February 17th 2026

FAQ concerning the Luxembourg Law of 17 December 2010 relating to undertakings for collective investment (Updated)

Version 23

AI Analysis

This CSSF FAQ (Version 23, updated 17 February 2026) provides interpretive guidance on the Luxembourg Law of 17 December 2010 relating to undertakings for collective investment (UCIs), covering UCITS, Part II UCIs, SIFs, and SICARs. It matters for compliance professionals as it clarifies authorisation processes, investment rules, and supervisory expectations, ensuring alignment with evolving EU frameworks like AIFMD and MiCAR. The update, effective today, addresses recent regulatory shifts including crypto-asset integration.

What Changed

- Authorisation Requirements: UCIs require CSSF approval of constitutive documents (articles, management regulations), depositary selection, and management company/AIFM applications for contractual...
Crypto-Asset Updates (aligned with separate but related FAQ Version 7): Replaces "virtual assets" with "crypto-assets" per MiCAR (EU 2023/1114); UCITS and retail AIFs (non-well-informed investors)...
Investment Policies and Liquidity Management: Funds must detail objectives, strategies, asset classes, restrictions, borrowing, and conflicts; look-through for intermediary vehicles per ESMA/AIFMD...
Risk Spreading Exemptions: Limits do not apply to OECD/EU-guaranteed securities or UCIs with comparable risk-spreading.
Depositary Role in Crypto: Luxembourg depositaries can custody crypto-assets with safeguards and CSSF notification; responsibility varies by model (depositary or MiCAR provider).

Suggested Considerations

Review and Update Documents: Align UCI constitutive documents, investment policies, and sales documents with clarified rules on strategies, LMTs, conflicts, and risk-spreading; apply look-through for intermediaries.
Crypto-Specific: For >10% NAV exposure, apply for "Other-Other Fund-Crypto-assets" extension (custody, valuation, AML/CFT plans, expertise); notify CSSF for depositary crypto custody; implement heightened AML/CFT due diligence per FATF/Luxembourg assessments.
Authorisation/Amendments: Submit for CSSF approval on new setups, manager changes, or sub-funds (esp. SICAV multi-sub-funds with EU cross-border services).
Governance and Reporting: Ensure RC/RR demonstrate crypto risk understanding; update disclosures for investors on risks, LMTs, and fair treatment.
Ongoing Compliance: Use FAQ/Compilation for RAIFs/SIFs/SICARs/Part II UCIs; auditors/managers confirm tax-exempt status for SICARs.

Key Dates

20 May 2025

Related AIFM FAQ Version 24; Introduces changes relevant to UCI managers acting as AIFMs

16 January 2026

UCI Authorisation page update; Reflects ongoing CSSF expectations for approvals

04 February 2026

Crypto FAQ Version 7 update effective; MiCAR-aligned changes on crypto exposure, authorisation extensions, and depositary notifications

17 February 2026 DEADLINE

FAQ Version 23 update effective; Applies immediately to UCI operations, authorisations, and compliance.[User-provided content]

Compliance Impact

Urgency: High – The update coincides with MiCAR implementation and today's release, requiring immediate review for crypto-exposed funds to avoid unauthorised strategies or AML gaps; non-compliance risks supervisory actions, authorisation delays, or investor disputes in Luxembourg's key fund domicile.

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

Topics:

Authorisation & Licensing Reporting & Disclosure AML / Financial Crime

Asset ManagerHedge FundAll Firms

Investment Management Wealth & Private Banking

🇱🇺 CSSF News medium

February 16th 2026

CSSF Annex to the Notification Letter under Article 33 of the AIFMD (Updated)

Version 3.1

Sectors:

Topics:

Asset ManagerWealth Manager

Banking & Credit Investment Management Wealth & Private Banking

🇱🇺 CSSF Warning high

February 13th 2026

Warning concerning the fraudulent activities carried out by Minea Global Finance SA

No description available.

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Authorisation & Licensing

BankWealth ManagerFintech

Banking & Credit Investment Management Wealth & Private Banking

🇦🇺 ASIC News low

February 13th 2026

Charge against NSW director dismissed

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Authorisation & Licensing

BankWealth ManagerAll Firms

Banking & Credit Crypto & Digital Assets

🇱🇺 CSSF Warning high

February 12th 2026

Warning concerning the website www.digitalasset-bank.com

No description available.

Sectors:

Topics:

BankFintechCrypto Exchange

Banking & Credit Consumer Credit Mortgage & Lending

🇱🇺 CSSF Guidance high

February 12th 2026

Circular letter

AML/CFT standardised data collection taking place in 2026

AI Analysis

The CSSF Circular Letter 2026-02-12 announces a standardized data collection exercise on AML/CFT for supervised entities, scheduled for 2026, aimed at enhancing regulatory oversight of money laundering and terrorist financing risks. This matters because it signals intensified CSSF scrutiny on AML/CFT compliance, requiring firms to prepare structured data submissions that could inform future supervisory actions, risk assessments, and enforcement. As part of broader CSSF AML/CFT initiatives, non-compliance risks fines or heightened inspections.

What Changed

- Introduction of standardized AML/CFT data collection: CSSF mandates uniform reporting formats for collecting data on AML/CFT risks, controls, and practices across supervised sectors, building on...
Alignment with ongoing AML/CFT enhancements: Complements recent governance-focused circulars (e.g., Circular 26/906 on central administration and risk management for payment/e-money institutions) by...
No explicit new obligations beyond preparation for data submission, but implies deeper integration of tax-related AML indicators and sub-sector risk updates, as seen in related CSSF activities.

Suggested Considerations

Assess and document AML/CFT data readiness: Inventory current risk assessments, transaction monitoring logs, KYC processes, SAR filings, and third-party oversight records in standardized formats; map to proportionality factors (e.g., transaction volumes, outsourcing).
Update governance and controls: Ensure compliance functions have independence, direct board reporting, and audit coverage of AML/CFT; test ICT resilience for monitoring continuity.
Conduct internal reviews: Perform gap analyses against Circular 26/906 (e.g., fund safeguarding, escalation protocols) and recent conference topics (e.g., terrorist financing, tax indicators); remediate deficiencies with board-approved plans.
Prepare for submission: Designate resources for data compilation; cooperate fully with CSSF/FIU requests, including transfer-of-funds information under EU 2015/847.
Engage auditors: Leverage approved auditors for validation of AML/CFT effectiveness ahead of collection.

Key Dates

2026 (exact date TBD) DEADLINE

Sectors:

Topics:

Consumer Protection / Conduct Authorisation & Licensing AML / Financial Crime

BankFintechAll Firms

🇦🇺 ASIC News high

February 10th 2026

No description available.

AI Analysis

The SFC reprimanded and fined Kylin International (HK) Co., Limited $9 million for systemic failures in managing private sub-funds from August 2018 to July 2021, including unmanaged conflicts of interest, inadequate reconciliations/valuations, weak KYC/suitability controls, AML/CTF record-keeping lapses, and misrepresentations to investors. This enforcement action underscores the SFC's heightened scrutiny of private fund managers, emphasizing senior management accountability and robust systems/controls to protect market integrity. Compliance professionals should note it as a deterrent signal, aligning with recent SFC circulars on escalating penalties for persistent misconduct.

What Changed

This is an enforcement action, not a new rule change, but it reinforces and exemplifies existing obligations under the Securities and Futures Ordinance (SFO), Fund Manager Code of Conduct (FMCC), and...
Mandatory conflict management and disclosure: Firms must identify, manage, and disclose conflicts, e.g., loans from the manager or directors to funds.
Asset reconciliation and valuation: Monthly reconciliations, regular valuations, and independent audits of fund financials are required.
KYC/suitability assessments: Adequate systems/controls for client due diligence and suitability, even for professional investors (no blanket exemptions).
AML/CTF compliance: Records must demonstrate ongoing adherence; misrepresentations to investors on exemptions are prohibited.

Suggested Considerations

Conduct gap analysis: Review private fund operations against five failure areas (conflicts, reconciliations/valuations/audits, KYC/suitability, AML/CTF records, investor representations) using FMCC and 9 Oct 2024 circular.
Enhance systems/controls: Implement monthly asset reconciliations, independent audits, automated KYC/suitability tools, and conflict registers; ensure AML/CTF records are audit-ready.
Senior management oversight: ROs/MICs to document personal accountability; train on self-reporting breaches (Code of Conduct para 12.5).
Investor communications: Cease any claims of suitability exemptions for professional investors; update disclosures.
Remediation evidence: Like Kylin, document post-review fixes to mitigate sanctions.

Key Dates

August 2018

July 2021; Period of Kylin's violations

Late 2020

SFC limited review prompted Kylin's remedial measures

31 December 2023

Kylin ceased regulated activities

9 October 2024

SFC circular on private fund deficiencies (immediate reference for remediation)

22 January 2025

SFC revoked Kylin's Type 9 license (following application)

Compliance Impact

Urgency: High - This signals SFC's enforcement escalation for private fund misconduct, with $9M fine despite clean record and remediation, prioritizing deterrence over mitigation. Firms face license revocation risks, personal sanctions on ROs/MICs (e.g., Wong/Zhu actions), and thematic inspections; non-compliance erodes investor confidence and invites harsher penalties per 2024 circular.

References

AI-generated analysis. May contain errors or omissions — verify with the original SFC source before acting. Full disclaimer.

Sectors:

AML / Financial Crime Consumer Protection / Conduct Senior Managers / Governance

Topics:

Asset Manager

Banking & Credit Investment Management Insurance & Pensions

🇿🇦 FSCA News high

February 7th 2026

Regulated People and Entities

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Authorisation & Licensing

BankAsset ManagerInsurance

Banking & Credit Investment Management Wealth & Private Banking

🇿🇦 FSCA News high

February 7th 2026

Sectors:

Topics:

Consumer Protection / Conduct AML / Financial Crime Authorisation & Licensing

Wealth ManagerBank

Banking & Credit Investment Management Insurance & Pensions

🇯🇵 JFSA News

February 4th 2026

Others,Updated English version of Reference Cases on Suspicious Transactions

No description available.

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Reporting & Disclosure

BankInsuranceAll Firms

Investment Management Crypto & Digital Assets Capital Markets & Trading

🇱🇺 CSSF Guidance high

February 4th 2026

The CSSF has updated its FAQ Crypto-Assets - Undertakings for collective investment (previously FAQ Virtual Assets - Undertakings for collective investment) and draws the attention to the following points

No description available.

AI Analysis

The Commission de Surveillance du Secteur Financier (CSSF) has updated its FAQ on crypto-asset investments by undertakings for collective investment, effective February 4, 2026, to align with the EU's Markets in Crypto-Assets Regulation (MiCAR). This update establishes clear investment limits and licensing requirements for UCITS and AIFs investing in crypto-assets, fundamentally reshaping how Luxembourg-regulated funds can structure crypto exposure.

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

Topics:

Authorisation & Licensing Prudential / Capital Requirements AML / Financial Crime

Asset ManagerHedge FundFintech

Investment Management Wealth & Private Banking

🇱🇺 CSSF Warning high

February 4th 2026

Warning concerning the website www.castleforbeswealth.com

No description available.

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Authorisation & Licensing

Wealth Manager

Banking & Credit Investment Management Wealth & Private Banking

🇦🇺 ASIC News high

February 4th 2026

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Operational Resilience / Outsourcing

BankWealth ManagerFintech

Banking & Credit Payments & E-Money Consumer Credit

🇸🇬 MAS News medium

February 3rd 2026

Written reply to Parliamentary Questions on the Shared Responsibility Framework and real-time fraud detection standards expected of financial institutions in Singapore

Written reply to Parliamentary Questions on the Shared Responsibility Framework and real-time fraud detection standards expected of financial institutions in Singapore.

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Operational Resilience / Outsourcing

BankFintechPayment Provider

Banking & Credit Capital Markets & Trading Investment Management

🇺🇸 CFTC News high

February 2nd 2026

Texas Resident to Pay Over $14 million for Misappropriation of Confidential Information, Illegal Kickbacks

No description available.

Sectors:

Topics:

AML / Financial Crime Market Abuse / Surveillance Reporting & Disclosure

BankBroker DealerHedge Fund

Banking & Credit Payments & E-Money Crypto & Digital Assets

🇩🇪 BaFin News high

February 2nd 2026

BaFin warns consumers about the website wefi(.)co

The Federal Financial Supervisory Authority (BaFin) warns consumers about the services offered on the website wefi(.)co. BaFin has information that this website is being used to offer banking business and cryptoasset services without the required authorisation.

Sectors:

Topics:

Authorisation & Licensing Consumer Protection / Conduct AML / Financial Crime

BankFintechCrypto Exchange

Banking & Credit Investment Management Wealth & Private Banking

🇱🇺 CSSF News high

February 2nd 2026

Council Implementing Regulation (EU) 2026/259 of 29 January 2026

implementing Regulation (EU) 2024/2642 concerning restrictive measures in view of Russia’s destabilising activities

Sectors:

Topics:

BankAsset ManagerWealth Manager

Banking & Credit Investment Management Wealth & Private Banking

🇩🇪 BaFin News high

February 2nd 2026

PCAM: BaFin warns against offers on the website pc-asset-management[.]com, in the app “PCAU pro,” and in WhatisApp groups

In the WhatsApp groups, investors are recommended by “Harrison T Blake” and “Francesca Müller” to invest in financial instruments that can then be traded via the aforementioned app or the platform pc-asset-management[.]com.

Sectors:

Topics:

Consumer Protection / Conduct Authorisation & Licensing AML / Financial Crime

BankWealth ManagerFintech

Banking & Credit Investment Management Wealth & Private Banking

🇦🇪 ADGM News medium

February 2nd 2026

02 Feb 2026 Read more

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Authorisation & Licensing

BankWealth ManagerFintech

Banking & Credit Payments & E-Money Capital Markets & Trading

🇨🇭 FINMA Enforcement critical

January 30th 2026

Aktualisierte Sanktionsmeldung: Russland

AI Analysis

On January 29, 2026, Switzerland's State Secretariat for Economic Affairs (SECO) reduced the price cap on Russian crude oil from USD 47.6 to USD 44.1 per barrel, effective February 1, 2026. This adjustment tightens existing sanctions enforcement and requires Swiss financial intermediaries to immediately implement updated compliance controls and reporting obligations under the Ukraine Sanctions Ordinance (SR 946.231.176.72).

AI-generated analysis. May contain errors or omissions — verify with the original FINMA source before acting. Full disclaimer.

Sectors:

Topics:

BankPayment ProviderAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇱🇺 CSSF News high

January 30th 2026

Council Implementing Regulation (EU) 2026/259 of 29 January 2026

implementing Regulation (EU) 2024/2642 concerning restrictive measures in view of Russia’s destabilising activities

Sectors:

Topics:

AML / Financial Crime Prudential / Capital Requirements Reporting & Disclosure

BankWealth ManagerAsset Manager

🇱🇺 CSSF Enforcement high

January 30th 2026

Administrative sanction of 1 December 2025

Administrative sanction imposed on a registered alternative investment fund manager (“AIFM”)

AI Analysis

The CSSF imposed an administrative fine of EUR 10,000 on registered alternative investment fund manager (AIFM) C5 S.à r.l. on 11 September 2025 for failing to submit its annual financial crime questionnaire by the 4 April 2025 deadline, despite reminders, breaching the cooperation obligation under Article 5(1) of Luxembourg's AML/CFT Law of 12 November 2004. This enforcement action underscores the CSSF's strict enforcement of AML reporting duties and serves as a warning to supervised entities on the consequences of non-compliance with supervisory requests. It matters because it demonstrates the CSSF's willingness to publish names and impose fines for procedural lapses, potentially signaling increased scrutiny on AIFMs' AML/CFT obligations amid broader regulatory focus on financial crime risks.

What Changed

This is not a regulatory change or new requirement but an enforcement precedent highlighting existing obligations under the AML/CFT Law:
Mandatory annual submission of the CSSF financial crime questionnaire by supervised entities, including registered AIFMs, as part of the cooperation duty in Article 5(1).
Fines determined per Article 8-4(1), (2)(f), and (3)(a), considering circumstances under Article 8-5(1), with publication assessed for proportionality under Article 8-6(1). No new rules introduced;...

Suggested Considerations

Immediate verification: Confirm timely submission of 2025 financial crime questionnaire (likely due April 2026 for 2025 data); review internal processes for CSSF reminders and automate alerts.
Procedural enhancements: Implement robust tracking systems for supervisory questionnaires, designate a responsible senior manager for AML cooperation, and document all responses or justifications for delays.
Training and testing: Conduct firm-wide training on AML/CFT Law Article 5(1) obligations; perform mock audits of reporting workflows, especially for registered AIFMs managing non-CSSF authorized funds.
Engagement protocol: Respond promptly to CSSF reminders; request in-person meetings if needed before fines escalate; review cooperation history to mitigate fine severity.
Policy updates: Align with CSSF Circular 25/894 for expanded AIFM reporting on unauthorized funds (notification within 10 working days for registered AIFMs).

Key Dates

4 April 2025 DEADLINE

- Deadline for submission of the annual financial crime questionnaire covering the year ending 31 December 2024

11 September 2025

- Date CSSF imposed the EUR 10,000 administrative fine on the AIFM for non-submission

9 January 2026

- Publication date of the sanction decision

30 January 2026

- Publication of the queried sanction notice (noting minor title discrepancy possibly referencing a separate but analogous case).[user provided]

Compliance Impact

Urgency: High – This sanction, though modest at EUR 10,000, exemplifies CSSF's proactive use of fines and public naming for AML reporting failures, with potential for higher penalties up to EUR 500,000 or 0.5% of turnover. It heightens risks for registered AIFMs amid CSSF's 2025-2026 priorities on financial crime, sanctions, and expanded reporting (e.g., Circular 25/894), where procedural lapses can trigger investigations, reputational damage, and barriers to remediation. Firms must prioritize to avoid escalation, especially post-publication on 30 January 2026.

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

AML / Financial Crime Reporting & Disclosure Authorisation & Licensing

Topics:

Asset ManagerHedge Fund

Banking & Credit Investment Management Wealth & Private Banking

🇦🇺 ASIC News high

January 29th 2026

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Authorisation & Licensing

BankWealth ManagerFintech

Banking & Credit Investment Management Wealth & Private Banking

🇨🇭 FINMA Enforcement high

January 27th 2026

Aktualisierte Sanktionsmeldung: Guatemala

Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung des Anhangs der Verordnung über Massnahmen betreffend Guatemala (SR 946.231.137.6) publiziert.

Sectors:

Topics:

BankWealth ManagerAll Firms

Banking & Credit Investment Management Capital Markets & Trading

🇯🇵 JFSA News medium

January 26th 2026

Publication,FSA Weekly Review No.672 January 26, 2026

No description available.

Sectors:

Topics:

AML / Financial Crime Prudential / Capital Requirements Reporting & Disclosure

BankAsset ManagerBroker Dealer

Banking & Credit Investment Management Capital Markets & Trading

🇭🇰 SFC News high

January 26th 2026

SFC suspends Wong Chi Fai for 27 months

No description available.

Sectors:

Topics:

AML / Financial Crime Market Abuse / Surveillance Authorisation & Licensing

Broker DealerAsset ManagerBank

Investment Management Capital Markets & Trading Capital Markets & Trading

🇺🇸 FINRA regulatory_notice critical

January 24th 2026

Enforcement Process

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Reporting & Disclosure

Broker DealerAsset ManagerWealth Manager

Banking & Credit Investment Management Capital Markets & Trading

🇺🇸 FINRA regulatory_notice low

January 24th 2026

Electronic Fingerprint Processing

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Reporting & Disclosure

Broker DealerAsset ManagerWealth Manager

Capital Markets & Trading Investment Management Wealth & Private Banking

🇺🇸 FINRA regulatory_notice low

January 24th 2026

Digital Experience Transformation (DXT)

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Reporting & Disclosure

Broker DealerAsset ManagerWealth Manager

Investment Management Capital Markets & Trading Consumer Credit

🇺🇸 FINRA regulatory_notice low

January 24th 2026

Customer Information Protection

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Reporting & Disclosure

Broker DealerAsset ManagerWealth Manager

Crypto & Digital Assets Capital Markets & Trading Investment Management

🇺🇸 FINRA regulatory_notice low

January 24th 2026

Crypto Assets

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Reporting & Disclosure

Crypto ExchangeBroker DealerAsset Manager

Banking & Credit Investment Management Capital Markets & Trading

🇺🇸 FINRA regulatory_notice medium

January 24th 2026

Credit for Cooperation

Sectors:

Topics:

AML / Financial Crime Reporting & Disclosure Authorisation & Licensing

Broker DealerAsset ManagerBank

Banking & Credit Investment Management Capital Markets & Trading

🇺🇸 FINRA regulatory_notice high

January 24th 2026

Anti-Money Laundering

Sectors:

Topics:

AML / Financial Crime Reporting & Disclosure Operational Resilience / Outsourcing

Broker DealerBankAsset Manager

Banking & Credit Investment Management Capital Markets & Trading

🇺🇸 FINRA regulatory_notice high

January 24th 2026

Regulatory Notice 25-11

Sectors:

Topics:

AML / Financial Crime Reporting & Disclosure Authorisation & Licensing

Broker DealerBankAsset Manager

Banking & Credit Investment Management Wealth & Private Banking

🇸🇦 SAMA News

January 24th 2026

With 40 Participants, SAMA Receives a Delegation from the Hong Kong Academy of Finance

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Authorisation & Licensing

BankWealth ManagerAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇦🇺 ASIC News high

January 24th 2026

Federal Court orders remaining ALAMMC Group companies wound up

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Prudential / Capital Requirements

BankAsset ManagerWealth Manager

Banking & Credit Investment Management Wealth & Private Banking

🇦🇺 ASIC News low

January 24th 2026

Two former Statewide Super executives acquitted on charges of dishonesty offences

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Prudential / Capital Requirements

BankWealth ManagerAsset Manager

Banking & Credit Investment Management Wealth & Private Banking

🇦🇺 ASIC News medium

January 24th 2026

Queensland director sentenced for making a false or misleading statement to ASIC

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Reporting & Disclosure

BankWealth ManagerAll Firms

🇦🇺 ASIC News high

January 24th 2026

ASIC secures interim travel restraint orders against Blockchain Global director Ryan Xu

Sectors:

Topics:

Crypto Exchange

Banking & Credit Investment Management Wealth & Private Banking

🇦🇺 ASIC News high

January 24th 2026

Construction industry director charged with breach of director’s duties and providing false and misleading documents

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Prudential / Capital Requirements

BankWealth ManagerAsset Manager

Banking & Credit Investment Management Wealth & Private Banking

🇦🇺 ASIC News high

January 24th 2026

Perth fraudster Chris Marco sentenced to 14 years imprisonment

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Prudential / Capital Requirements

BankWealth ManagerAsset Manager

Banking & Credit Investment Management Wealth & Private Banking

🇦🇺 ASIC News low

January 24th 2026

Charges against Dean Scook, former officer of Rock Mining Australia Limited, have been discontinued

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Authorisation & Licensing

BankWealth ManagerAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇦🇺 ASIC News high

January 24th 2026

Freezing orders against Gregory Cotton and First Mutual Private Equity continue

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Prudential / Capital Requirements

BankWealth ManagerAsset Manager

Banking & Credit Investment Management Wealth & Private Banking

🇦🇺 ASIC News high

January 24th 2026

Mansa Group director sentenced to imprisonment for more than four years for forgery and dishonesty offences

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Prudential / Capital Requirements

BankWealth ManagerAsset Manager

Banking & Credit Investment Management Wealth & Private Banking

🇦🇺 ASIC News high

January 24th 2026

QLD shadow director charged with $8m debt factoring fraud involving Bunnings Warehouse

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Authorisation & Licensing

BankWealth ManagerFintech

Banking & Credit Investment Management Wealth & Private Banking

🇦🇺 ASIC News high

January 24th 2026

Banned SMSF Auditor charged with continuing to act whilst disqualified and falsifying documents

Sectors:

Topics:

AML / Financial Crime Authorisation & Licensing Senior Managers / Governance

Asset ManagerWealth ManagerBank

Banking & Credit Investment Management Wealth & Private Banking

🇦🇺 ASIC News high

January 24th 2026

ASIC takes contempt action against David McWilliams and Laura Fullarton over alleged freezing order breaches

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Prudential / Capital Requirements

BankWealth ManagerFintech

Banking & Credit Investment Management Wealth & Private Banking

🇦🇺 ASIC News

January 24th 2026

Former CEO of Bruck Textile Technologies has conviction overturned following appeal

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Authorisation & Licensing

BankWealth ManagerAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇦🇺 ASIC News high

January 24th 2026

ASIC sues BDO Audit and its director Dean Just alleging materially false or misleading audit reports

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Reporting & Disclosure

BankWealth Manager

Banking & Credit Consumer Credit Mortgage & Lending

🇦🇺 ASIC News high

January 24th 2026

Sectors:

Topics:

Authorisation & Licensing Consumer Protection / Conduct AML / Financial Crime

BankFintech

Banking & Credit Investment Management Capital Markets & Trading

🇭🇰 SFC News high

January 21st 2026

SFC obtains $595 million compensation order and disqualification orders up to 15 years against three former directors and senior executives of Superb Summit International Group Limited

No description available.

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Prudential / Capital Requirements

BankBroker DealerAsset Manager

Banking & Credit Wealth & Private Banking Payments & E-Money

🇱🇺 CSSF News medium

January 20th 2026

Publication of the update of the ML/FT Sub-Sector Risk Assessment on Specialised Professionals of the Financial Sector providing corporate services (trust and company service provider activities)

No description available.

Sectors:

Topics:

AML / Financial Crime Authorisation & Licensing Reporting & Disclosure

BankWealth ManagerPayment Provider

AML / Financial Crime Consumer Protection / Conduct Authorisation & Licensing

🇱🇺 CSSF Guidance high

January 20th 2026

Circular CSSF 26/906

Central administration, internal governance and risk management

AI Analysis

Circular CSSF 26/906, published on 20 January 2026, consolidates and clarifies Luxembourg's rules on central administration, internal governance, and risk management specifically for payment institutions, electronic money institutions, and account information service providers. It repeals prior circulars (IML 95/120, IML 96/126, IML 98/143, and CSSF 04/155) to address growth in transaction volumes by mandating robust governance, control functions, and risk processes, enhancing safety, efficiency, and trust in these services. This matters for compliance professionals as it strengthens defenses against financial crime, operational risks, and supervisory scrutiny in a high-growth sector.

What Changed

- Consolidation and repeal: Replaces outdated circulars with unified requirements under the amended Law of 10 November 2009 on payment services, covering central administration (decision-making must...
Governance enhancements: Board approves strategy, risk appetite, AML/CFT policies, outsourcing, and information security; management implements via procedures; proportionality based on business...
Operational controls: Strict access to systems (need-to-know, least-privilege, 4-eyes validation); counterparty due diligence for custodians/insurers; full responsibility for agents, distributors,...
AML/CFT focus: Elevates compliance function independence, direct board reporting, risk-based resourcing, and oversight of third parties/opaque structures to close gaps exploited by criminals.

Suggested Considerations

Assess and update governance frameworks: Review central administration location, board/management responsibilities, risk strategy, AML/CFT policies, compliance charter, and funds safeguarding principles to align with the circular.
Confirm control functions: Ensure compliance function (CCO) has independence, resources, direct board access, and authority for investigations; justify/secure CSSF approval for part-time/dual roles.
Implement operational safeguards: Establish daily reconciliations (or justified weekly), segregation/insurance for client funds, system access controls (4-eyes, board validation for significant movements), and third-party due diligence/monitoring.
Document proportionality: Tailor governance to business risks (staff, volumes, products, outsourcing); update new product approval, conflicts policies, and business continuity/incident reporting.
Retain records and report: Board-approve all key policies; prepare for CSSF inspections on outsourcing (per Circular CSSF 22/806) and ICT risks.

Key Dates

BankWealth ManagerFintech

Banking & Credit Investment Management Wealth & Private Banking

🇦🇪 ADGM News high

January 16th 2026

Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung des Anhangs 2 der Verordnung vom 22. Juni 2005 über Massnahmen gegenüber der Demokratischen Republik Kongo (SR 946.231.12) publiziert.

AI Analysis

The Swiss Federal Department for Economic Affairs, Education and Research (WBF) updated Annex 2 of the Ordinance on Measures against the Democratic Republic of Congo (SR 946.231.12) on January 12, 2026, modifying the list of sanctioned persons, companies, and organizations, with changes effective January 13, 2026, at 23:00 UTC. This matters for Swiss financial intermediaries as it triggers immediate asset freezing, reporting to SECO, and potential AML checks under the Anti-Money Laundering Act (GwG), ensuring compliance with Switzerland's implementation of international sanctions via the Embargo Act (EmbG).

What Changed

- Amendment to Annex 2 of SR 946.231.12, updating the list of sanctioned individuals, entities, and organizations subject to financial restrictions.
Integration into the SECO Sanctions Management (SESAM) database, with urgent publication on the SECO website.
Reinforcement of prohibitions: asset freezing, ban on making funds available, and reporting of affected business relationships to SECO; does not exempt from GwG Art. 6 due diligence or Art.

Suggested Considerations

Screen client portfolios and transactions against the updated SESAM database immediately upon effectiveness.
Freeze assets of newly listed sanctioned parties and prohibit making funds/resources available.
Report affected business relationships to SECO without delay.
Conduct GwG Art. 6 due diligence on suspicions; file Art. 9 reports to the Money Laundering Reporting Office if unresolved.
Monitor MyFINMA for FINMA alerts and update internal sanctions screening tools.

Key Dates

January 12, 2026

- WBF publishes amendment to Annex 2

January 13, 2026, 23:00 UTC DEADLINE

- Changes enter into force; immediate implementation required

December 12, 2026

- Related EU sanctions extended to this date (Swiss alignment expected)

Compliance Impact

Urgency: High - Immediate effect from January 13, 2026, 23:00 UTC demands rapid screening and freezing to avoid EmbG violations, which can trigger FINMA enforcement (e.g., fines, license actions). Matters due to sanctions lists' frequent updates (e.g., prior May 2024 change) and overlap with AML obligations, heightening financial crime exposure for DRC-linked assets.

References

AI-generated analysis. May contain errors or omissions — verify with the original FINMA source before acting. Full disclaimer.

Sectors:

Topics:

BankAsset ManagerWealth Manager

Banking & Credit Wealth & Private Banking Investment Management

🇨🇭 FINMA Enforcement critical

January 13th 2026

Aktualisierte Sanktionsmeldung: Venezuela

Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat Änderungen des Anhangs 1 der Verordnung vom 28. März 2018 über Massnahmen gegenüber Venezuela (SR 946.231.178.5) publiziert.

AI Analysis

On January 13, 2026, Switzerland's State Secretariat for Economic Affairs (SECO) updated Annex 1 of the Ordinance on Measures against Venezuela (SR 946.231.178.5), reflecting changes to the list of designated persons and entities subject to Swiss asset freezing measures. This update is critical for Swiss financial institutions and regulated entities as it directly impacts sanctions compliance obligations and requires immediate verification of client and counterparty lists against the revised designations.

What Changed

The regulatory update modifies the designated persons list under Switzerland's unilateral freezing measures against Venezuela.
Update their sanctions screening systems with revised designations
Identify any existing relationships with newly designated or de-designated persons/entities
Implement immediate asset freezing for any newly added designations
Cease all transactions with blocked parties unless specifically authorized

Suggested Considerations

*Immediate Screening: Conduct comprehensive screening of all client and counterparty databases against the updated Annex 1 designations within 24-48 hours of publication.
*Asset Identification: Identify and document any assets, accounts, or positions held by or on behalf of newly designated persons/entities.
*Freeze Implementation: Immediately freeze all identified assets and block all transactions involving designated parties.
*Notification: Report any blocked assets to SECO as required under Swiss sanctions legislation (typically within 10 business days).
*Transaction Review: Suspend all pending transactions with Venezuela-related counterparties pending compliance verification.

Key Dates

January 5, 2026

- FINMA ordinance on asset freezing (RS 196.127.85) enters into force at 11 a.m., freezing assets of 37 designated persons

January 13, 2026

- SECO publishes updated Annex 1 to SR 946.231.178.5 (the update referenced in your query)

Immediate DEADLINE

- Compliance obligations commence upon publication; no grace period for implementation

Compliance Impact

Urgency: CRITICAL

References

AI-generated analysis. May contain errors or omissions — verify with the original FINMA source before acting. Full disclaimer.

Sectors:

Topics:

AML / Financial Crime Reporting & Disclosure Authorisation & Licensing

BankWealth ManagerAsset Manager

Banking & Credit Payments & E-Money Crypto & Digital Assets

🇨🇭 FINMA Enforcement high

January 13th 2026

Aktualisierte Sanktionsmeldung: Russland

AI Analysis

The Swiss Federal Department for Economic Affairs, Education and Research (WBF) has published updates to the Ordinance on Measures in Connection with the Situation in Ukraine (SR 946.231.176.72), aligning Swiss sanctions with ongoing international restrictions targeting Russia. This matters for Swiss financial institutions as it reinforces asset freezing and economic resource restrictions, heightening compliance risks amid prolonged geopolitical tensions, with the ordinance valid until at least November 2026.

What Changed

The publication announces amendments to SR 946.231.176.72, though specific details in the notice are limited; it signals ongoing refinements to sanctions measures originally enacted on March 4, 2022. Related documentation indicates persistent expansions, such as broader restrictions on Russian energy sector activities (e.g., prohibiting certain services, financing, and transactions), definitions encompassing financial instruments like derivatives, crypto-assets, and securitizations, and prohibitions on asset management or use except for normal administrative actions by financial institutions.

Suggested Considerations

Screen clients, transactions, and assets against updated sanctions lists for Russian/Ukrainian designations, focusing on asset freezing (no management/use except administrative actions) and economic resources (no sales, leasing, or financing).
Block prohibited activities in energy sector, financial services (e.g., derivatives, crypto, guarantees), and related exports/financing; report any frozen assets to authorities.
Update internal policies, screening tools, and training to reflect changes; maintain records of compliance checks and authorizations (if applicable under Article 11).
Monitor FINMA's sanctions page for full ordinance text and related guidance.

Key Dates

Various historical dates (e.g., March 25, 2022 at 23:00; January 25, 2023 at 18:00)

- Prior amendment effective dates, illustrating pattern of rapid implementation

January 13, 2026

- Publication of amendments by WBF, triggering immediate review obligations

November 22, 2026

- Current expiry of ordinance (subject to extension)

Compliance Impact

Urgency: High - Ongoing amendments to this long-standing ordinance (active since 2022) demand immediate screening and blocking to avoid FINMA enforcement, fines, or reputational damage, especially with crypto and energy sector expansions capturing evolving risks. Non-compliance risks asset release violations or facilitation of sanctioned activities, amplified by FINMA's enforcement focus on financial crime.

References

AI-generated analysis. May contain errors or omissions — verify with the original FINMA source before acting. Full disclaimer.

Sectors:

Topics:

BankPayment ProviderCrypto Exchange

Banking & Credit Payments & E-Money

🇱🇺 CSSF Enforcement high

January 12th 2026

Population concerned by the enforcement

No description available.

AI Analysis

This CSSF publication, dated January 12, 2026, identifies the specific population (likely a firm or individual) subject to an enforcement action, such as an administrative sanction, as part of the CSSF's transparency in supervisory measures. It matters because it signals CSSF's active enforcement priorities, potentially in areas like AML or reporting failures, enabling firms to assess similar risks in their operations and strengthen compliance to avoid parallel actions. Published amid rising focus on financial crime typologies like sexual extortion, it underscores the regulator's commitment to public accountability.

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

Topics:

AML / Financial Crime Reporting & Disclosure Authorisation & Licensing

BankPayment ProviderAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇱🇺 CSSF News high

January 12th 2026

Commission Delegated Regulation (EU) 2026/46 of 3 December 2025

amending Delegated Regulation (EU) 2016/1675 to add Russia to the list of high-risk third countries with strategic deficiencies

Sectors:

Topics:

AML / Financial Crime Prudential / Capital Requirements Authorisation & Licensing

BankAsset ManagerWealth Manager

Banking & Credit Investment Management Wealth & Private Banking

🇬🇧 FCA News high

January 9th 2026

FCA obtains £265,523.96 confiscation order against Collateral fraudster Andrew Currie

The FCA has secured a confiscation order of £265,523.96 against Andrew Currie. Mr Currie was convicted in 2023 and sentenced to 2 years 6 months imprisonment for defrauding investors through the collapsed peer-to-peer lending platform Collateral (UK) Ltd.He diverted funds from Collateral investors and used them for personal gain, including the purchase of a property in Spain.At a hearing at Southwark Crown Court on 9 January 2026, Mr Currie was ordered to pay £265,523.96. This amount represen...

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Prudential / Capital Requirements

BankWealth ManagerFintech

🇱🇺 CSSF Enforcement medium

January 9th 2026

Administrative sanction of 11 September 2025

Administrative sanction imposed on the alternative investment fund manager Premium Capital Management (“AIFM”)

AI Analysis

The CSSF imposed a €10,000 administrative fine on 11 September 2025 against alternative investment fund manager (AIFM) Premium Capital Management for failing to submit its annual financial crime questionnaire by the 4 April 2025 deadline, breaching the cooperation obligation under Article 5(1) of Luxembourg's AML/CFT Law of 12 November 2004. This enforcement action underscores the CSSF's strict enforcement of AML reporting duties, signaling heightened scrutiny on timely supervisory cooperation amid ongoing AML risks in Luxembourg. Compliance teams should view this as a reminder of the low tolerance for even administrative lapses, with potential for escalated fines in repeat cases.

What Changed

This is not a regulatory change but an enforcement precedent under existing rules: non-compliance with Article 5(1) of the AML/CFT Law, which mandates annual submission of a financial crime questionnaire ("Questionnaire") to the CSSF. The fine was calculated per Articles 8-4(1), 8-4(2)(f), and 8-4(3)(a), considering circumstances under Article 8-5(1). Publication followed Article 8-6(1) after a proportionality assessment, confirming no market stability risks.

Suggested Considerations

Immediately review internal processes for annual Questionnaire submission, ensuring calendar invites and automated reminders for the 4 April deadline (covering prior year-end data).
Conduct a gap analysis on AML/CFT cooperation obligations under Article 5(1), including response protocols to CSSF reminders or queries.
Update compliance calendars and train staff on escalation procedures; document all submissions with proof (e.g., timestamps, acknowledgments).
For AIFMs: Verify CSSF registration status under Article 3(2) of the 12 July 2013 AIFM Law and align with broader AML duties.
If late, proactively submit overdue items and request meetings if needed, as non-response forfeits mitigation opportunities.

Key Dates

31 December 2024

- Reference year-end for the financial crime Questionnaire

4 April 2025 DEADLINE

- Statutory deadline for Questionnaire submission to CSSF

11 September 2025

- Date CSSF imposed the €10,000 administrative fine after non-submission despite reminders

9 January 2026

- Publication date of the sanction decision

Compliance Impact

Urgency: Medium – This €10,000 fine for a straightforward reporting failure demonstrates CSSF's willingness to penalize non-cooperation swiftly, even without aggravating factors, but the amount is modest and targeted at administrative breaches. It matters as a warning shot in Luxembourg's AML landscape, where repeated failures could trigger higher fines (up to proportionality limits under Article 8-5), reputational damage via public naming, or supervisory escalations; firms should audit 2025/2026 reporting now to preempt similar actions, especially post-NRA updates.

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

AML / Financial Crime Authorisation & Licensing Reporting & Disclosure

Topics:

Asset ManagerHedge Fund

🇱🇺 CSSF Enforcement high

January 9th 2026

Administrative sanction of 11 September 2025

Administrative sanction imposed on the alternative investment fund manager Sunbricks GP S.à r.l. (“AIFM”)

AI Analysis

The CSSF imposed a **€10,000 administrative fine on Sunbricks GP S.à r.l.**, an alternative investment fund manager, for failing to submit a mandatory annual financial crime questionnaire by the April 4, 2025 deadline, despite two formal reminders. This enforcement action demonstrates the CSSF's strict approach to cooperation obligations under Luxembourg's anti-money laundering and counter-terrorist financing (AML/CFT) framework and signals that non-submission of required compliance documentation—even without evidence of underlying financial crime—triggers regulatory penalties.

What Changed

This is not a regulatory change but rather an enforcement action clarifying existing obligations:
Mandatory Annual Questionnaire Requirement: All professionals supervised, authorized, or registered by the CSSF must submit an annual questionnaire on financial crime by April 4 each year, covering...
Cooperation Obligation: Article 5(1) of the amended Law of 12 November 2004 on AML/CFT establishes a non-negotiable duty to cooperate with the CSSF, which includes timely submission of requested...
Administrative Fine Framework: The CSSF applies Article 8-4 of the AML/CFT Law to impose fines for non-compliance, with amounts determined under Article 8-5 based on all relevant circumstances.

Suggested Considerations

regulated entities must:
*Establish Calendar Controls: Implement internal compliance calendars flagging the April 4 annual questionnaire submission deadline with sufficient lead time (minimum 4-6 weeks before deadline)
*Designate Responsible Parties: Assign clear ownership for questionnaire completion and submission, with backup contacts
*Prepare Documentation: Maintain contemporaneous records of financial crime controls, suspicious activity reporting, and compliance activities throughout the year to support accurate questionnaire responses
*Monitor Communications: Ensure all CSSF correspondence is tracked and escalated immediately; do not ignore reminder notices

Key Dates

April 4, 2025 DEADLINE

– Annual financial crime questionnaire submission deadline (for year ending December 31, 2024)

Before September 11, 2025

– Two reminder notices issued by CSSF to Sunbricks GP

September 11, 2025

– Administrative fine decision date; questionnaire still not submitted

January 9, 2026

– Publication date of enforcement decision

Compliance Impact

Urgency: HIGH

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

AML / Financial Crime Authorisation & Licensing Reporting & Disclosure

Topics:

Asset ManagerAll Firms

🇱🇺 CSSF Enforcement medium

January 9th 2026

Administrative sanction of 11 September 2025

Administrative sanction imposed on the alternative investment fund manager Capitalis Premiere Group (“AIFM”)

AI Analysis

The CSSF imposed a €10,000 administrative fine on alternative investment fund manager (AIFM) Capitalis Premiere Group on 11 September 2025 for failing to submit its annual financial crime questionnaire by the 4 April 2025 deadline, despite two reminders, breaching the cooperation obligation under Article 5(1) of Luxembourg's AML/CFT Law of 12 November 2004. This enforcement action underscores the CSSF's strict enforcement of AML reporting duties, signaling heightened scrutiny on timely supervisory cooperation for Luxembourg-regulated entities. Compliance teams should note this as a low-value but public reminder of potential fines for administrative lapses in AML processes.

What Changed

This is not a regulatory change or new requirement but an enforcement precedent under existing rules: non-compliance with the annual financial crime questionnaire submission, mandated by Article 5(1) of the AML/CFT Law, triggers fines per Articles 8-4(1), 8-4(2)(f), and 8-4(3)(a). The CSSF considered all relevant circumstances under Article 8-5(1) to set the €10,000 fine amount and published the sanction nominatively after proportionality assessment per Article 8-6(1), confirming no market stability risks.

Suggested Considerations

Ensure timely submission of annual financial crime questionnaires by 4 April each year (for prior calendar year data); implement calendar reminders and escalation processes for CSSF requests.
Respond promptly to CSSF reminders or queries on AML/CFT compliance to avoid escalation to fines; document any delays with justification evidence.
Review internal AML cooperation protocols, including governance for questionnaire completion, and train staff on Article 5(1) obligations; consider requesting in-person meetings if disputing CSSF demands.
No retroactive actions needed for this case, but conduct gap analysis on reporting workflows to prevent similar breaches.

Key Dates

4 April 2025 DEADLINE

- Deadline for submitting the annual financial crime questionnaire covering the year ending 31 December 2024

11 September 2025

- Date CSSF imposed the €10,000 administrative fine on Capitalis Premiere Group for non-submission

9 January 2026

- Date of CSSF publication of the sanction decision

Compliance Impact

Urgency: Medium - This €10,000 fine is modest but publicly names the firm, amplifying reputational risk in Luxembourg's competitive fund domicile; it matters as a clear CSSF signal of zero tolerance for basic cooperation failures in AML, potentially foreshadowing stricter enforcement amid EU AML harmonization pressures. AIFMs face ongoing annual risk, with non-response despite reminders treated as willful breach; firms with weak reporting controls should prioritize fixes to avoid cumulative fines or escalations.

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

AML / Financial Crime Reporting & Disclosure Authorisation & Licensing

Topics:

Asset ManagerHedge Fund

🇱🇺 CSSF Enforcement high

January 9th 2026

Administrative sanction of 11 September 2025

Administrative sanction imposed on the alternative investment fund manager Lion Management (“AIFM”)

AI Analysis

The CSSF imposed a €10,000 administrative fine on Lion Management, an alternative investment fund manager, on 11 September 2025 for failing to submit a mandatory annual financial crime questionnaire by the 4 April 2025 deadline. This enforcement action demonstrates the CSSF's commitment to enforcing cooperation obligations under Luxembourg's anti-money laundering and terrorist financing framework, with direct implications for all AIFMs regarding timely compliance with supervisory reporting requirements.

What Changed

This is not a regulatory change but rather an enforcement action clarifying existing obligations. However, it reinforces critical compliance requirements:
Mandatory Annual Questionnaire Submission: All CSSF-supervised professionals, including AIFMs, must submit an annual questionnaire on financial crime by the specified deadline (in this case, 4 April...
Cooperation Obligation: Article 5(1) of the amended Law of 12 November 2004 on the fight against money laundering and terrorist financing establishes a non-negotiable obligation to cooperate with the...
Enforcement Escalation: The CSSF will issue reminders before imposing sanctions, but failure to respond to reminders results in administrative fines determined under Article 8-4 of the AML/CFT Law.

Suggested Considerations

*Establish Calendar Controls: Implement firm-wide systems to track the annual financial crime questionnaire deadline (typically 4 April for the prior calendar year)
*Designate Responsible Parties: Assign clear ownership for questionnaire completion and submission to the CSSF, with escalation procedures
*Monitor CSSF Communications: Establish protocols to immediately flag and respond to any CSSF correspondence, including reminders or requests for information
*Document Submission: Maintain evidence of timely submission (timestamps, confirmation receipts) to demonstrate compliance
*Escalate Non-Compliance Immediately: If submission cannot be met by deadline, proactively contact the CSSF to explain delays and request extensions rather than ignoring reminders

Key Dates

4 April 2025 DEADLINE

- Deadline for submission of annual financial crime questionnaire for year ending 31 December 2024

11 September 2025

- Date CSSF imposed administrative fine after two reminders went unheeded

9 January 2026

- Publication date of the administrative sanction decision

Compliance Impact

Urgency: HIGH

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

AML / Financial Crime Reporting & Disclosure Authorisation & Licensing

Topics:

Asset ManagerHedge Fund

🇱🇺 CSSF Enforcement high

January 9th 2026

Administrative sanction of 11 September 2025

Administrative sanction imposed on the alternative investment fund manager Max Gain Capital S.à r.l. (“AIFM”)

AI Analysis

The CSSF imposed a €10,000 administrative fine on Max Gain Capital S.à r.l., an alternative investment fund manager, on 11 September 2025 for failing to submit a mandatory annual financial crime questionnaire by the April 2025 deadline. This enforcement action demonstrates the CSSF's active monitoring of AML/CFT compliance obligations and its willingness to sanction non-cooperation, even for procedural failures unrelated to substantive money laundering violations.

What Changed

This is not a regulatory change but rather an enforcement action clarifying existing obligations:
Mandatory Annual Questionnaire Requirement: All CSSF-supervised professionals must submit an annual questionnaire on financial crime covering the preceding calendar year.
Cooperation Obligation: Article 5(1) of the amended Law of 12 November 2004 on AML/CFT imposes a non-negotiable duty to cooperate with CSSF supervisory requests.
Enforcement Escalation: The CSSF will issue reminders before imposing sanctions, but continued non-compliance triggers administrative fines under Article 8-4 of the AML/CFT Law.

Suggested Considerations

regulated entities must:
*Identify Reporting Obligations: Confirm whether your firm is subject to the annual financial crime questionnaire requirement under Article 5(1) of the AML/CFT Law
*Calendar Management: Establish internal processes to ensure questionnaires are submitted by 4 April each year for the preceding calendar year
*Documentation: Maintain records demonstrating timely submission and preserve evidence of compliance
*Escalation Protocol: If unable to meet deadlines, proactively contact the CSSF to request extensions or clarification rather than ignoring reminders

Key Dates

4 April 2025 DEADLINE

- Deadline for submission of financial crime questionnaire for the year ending 31 December 2024

Before 11 September 2025 DEADLINE

- CSSF issued two reminders to Max Gain Capital after the missed deadline

11 September 2025

- CSSF imposed the €10,000 administrative fine

9 January 2026

- CSSF published the administrative sanction decision

Compliance Impact

Urgency: HIGH

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

AML / Financial Crime Authorisation & Licensing Senior Managers / Governance

Topics:

Asset ManagerAll Firms

🇱🇺 CSSF Enforcement high

January 9th 2026

Administrative sanction of 11 September 2025

Administrative sanction imposed on the alternative investment fund manager Agriland Management S.A. (“AIFM”)

AI Analysis

The Commission de Surveillance du Secteur Financier (CSSF), Luxembourg's financial regulator, imposed a **EUR 10,000 administrative fine on Agriland Management S.A.**, an alternative investment fund manager, on 11 September 2025 for failing to submit a mandatory annual financial crime questionnaire by the April 2025 deadline. This enforcement action demonstrates the CSSF's commitment to enforcing cooperation obligations under Luxembourg's anti-money laundering and terrorist financing (AML/CFT) framework and signals heightened scrutiny of compliance with supervisory reporting requirements.

What Changed

This is not a regulatory change but rather an enforcement action that clarifies existing obligations:
Mandatory Annual Reporting: All CSSF-supervised professionals must submit an annual questionnaire on financial crime by 4 April each year, covering the preceding calendar year.
Cooperation Obligation: Article 5(1) of the amended Law of 12 November 2004 on AML/CFT establishes a non-negotiable duty to cooperate with the CSSF, including timely submission of requested...
Enforcement Escalation: The CSSF will issue reminders for non-compliance, but continued failure to respond triggers administrative sanctions without requiring evidence of intentional misconduct.

Suggested Considerations

*Establish Reporting Calendars: Implement systems to track the 4 April annual deadline for financial crime questionnaire submissions
*Designate Responsible Personnel: Assign clear accountability for completing and submitting the questionnaire to the CSSF
*Respond to Regulatory Requests: Do not ignore CSSF reminders; engage proactively, including requesting in-person meetings if clarification is needed
*Document Justifications: If unable to meet deadlines, provide written evidence explaining the delay and proposed remediation timeline
*Monitor Supervisory Communications: Establish procedures to ensure regulatory correspondence is tracked and escalated appropriately

Key Dates

4 April 2025 DEADLINE

– Deadline for submission of financial crime questionnaire for year ending 31 December 2024

Before 11 September 2025

– Two reminder notices issued by CSSF to Agriland Management S.A

11 September 2025

– Administrative fine imposed

9 January 2026

– Sanction published by CSSF

Compliance Impact

Urgency: HIGH

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

AML / Financial Crime Reporting & Disclosure Authorisation & Licensing

Topics:

Asset Manager

🇱🇺 CSSF Enforcement medium

January 9th 2026

Administrative sanction of 11 September 2025

Administrative sanction imposed on the alternative investment fund manager Bedrock I GP S.à r.l. (“AIFM”)

AI Analysis

The CSSF imposed a €10,000 administrative fine on alternative investment fund manager (AIFM) Bedrock I GP S.à r.l. on 11 September 2025 for failing to submit its annual financial crime questionnaire by the 4 April 2025 deadline, despite two reminders, breaching the cooperation obligation under Article 5(1) of Luxembourg's AML/CFT Law of 12 November 2004. This enforcement action underscores CSSF's strict enforcement of AML reporting duties and serves as a public warning to supervised entities on timely supervisory compliance. It matters because it demonstrates that even modest fines are pursued for basic reporting lapses, potentially signaling heightened scrutiny on AIFMs' AML processes amid ongoing regulatory focus on financial crime risks.

What Changed

This is not a regulatory change or new requirement but an enforcement of existing obligations under the amended Law of 12 November 2004 on the fight against money laundering and terrorist financing (AML/CFT Law). Specifically, it reaffirms the mandatory annual submission of the CSSF's financial crime questionnaire ("Questionnaire") by supervised professionals, including AIFMs under Article 3(2) of the Law of 12 July 2013 on AIFMs, as part of the cooperation duty in Article 5(1).

Suggested Considerations

Immediately verify submission status of the 2024 Questionnaire (or any outstanding); if overdue, submit promptly with justification to mitigate further escalation.
Implement automated calendar alerts and internal workflows for all CSSF reporting deadlines, including annual AML/CFT Questionnaire.
Conduct a compliance gap analysis on cooperation obligations under Article 5(1) AML/CFT Law, documenting reminder responses and evidence retention.
Train senior managers and compliance teams on supervisory interactions, including rights to request in-person meetings before fines.
Review governance for timely escalation of CSSF reminders to decision-makers.

Key Dates

31 December 2024 DEADLINE

- Reference period end for the Questionnaire covering financial crime compliance

4 April 2025 DEADLINE

- Statutory deadline for Questionnaire submission to CSSF

11 September 2025

- Date of administrative fine imposition (€10,000) after non-submission despite reminders

9 January 2026

- Publication date of the sanction decision by CSSF

Compliance Impact

Urgency: Medium - This is a post-facto enforcement on a past breach (2024 reporting cycle), with the €10,000 fine relatively low, indicating proportionality for a first-time or isolated lapse. It matters as a leading indicator of CSSF's 2025-2026 focus on AML cooperation, with multiple similar AIFM sanctions published simultaneously, risking escalated fines or reputational harm for repeat offenders; firms should prioritize reporting hygiene to avoid public naming, which CSSF deems non-disruptive to markets here.

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

AML / Financial Crime Reporting & Disclosure Authorisation & Licensing

Topics:

Asset ManagerHedge Fund

🇱🇺 CSSF Enforcement medium

January 9th 2026

Administrative sanction of 11 September 2025

Administrative sanction imposed on the alternative investment fund manager C5 Haven Cyber GP S.à r.l. (“AIFM”)

AI Analysis

The CSSF imposed a €10,000 administrative fine on alternative investment fund manager (AIFM) C5 Haven Cyber GP S.à r.l. on 11 September 2025 for failing to submit its annual financial crime questionnaire by the 4 April 2025 deadline, despite two reminders, breaching the cooperation obligation under Article 5(1) of Luxembourg's AML/CFT Law of 12 November 2004. This enforcement action underscores CSSF's strict enforcement of AML reporting duties and serves as a public warning to supervised entities on the consequences of non-cooperation. It matters because it demonstrates that even modest fines will be levied for procedural lapses, potentially signaling increased scrutiny on timely AML compliance submissions amid broader regulatory focus on financial crime risks.

What Changed

This is not a regulatory change or new requirement but an enforcement of existing obligations under the amended AML/CFT Law:
Annual Questionnaire Submission: Supervised professionals, including AIFMs under Article 3(2) of the Law of 12 July 2013 on AIFMs, must submit an annual financial crime questionnaire...
Fine Provisions: Fines are imposed per Articles 8-4(1), 8-4(2)(f), and 8-4(3)(a), with amounts determined by relevant circumstances under Article 8-5(1); publication follows Article 8-6(1) after...

Suggested Considerations

Immediate Review: AIFMs and similar entities must verify their internal processes for annual Questionnaire submission, ensuring calendar reminders and automated tracking for 4 April deadlines.
Remediation if Late: Submit overdue Questionnaires promptly with explanations; request in-person meetings if needed, as the sanctioned AIFM failed to do so.
Process Enhancements: Implement escalation protocols for CSSF reminders, designate a senior compliance officer for oversight, and document all submissions/acknowledgments to demonstrate cooperation under Article 5(1).
Training: Conduct firm-wide training on AML/CFT cooperation duties, emphasizing that non-response leads to fines without need for justification.

Key Dates

31 December 2024

- Reference year-end for the financial crime Questionnaire

4 April 2025 DEADLINE

- Statutory deadline for submitting the Questionnaire for the year ending 31 December 2024

11 September 2025

- Date CSSF imposed the €10,000 administrative fine after noting non-submission despite reminders

9 January 2026

- Date of CSSF publication of the sanction decision

Compliance Impact

Urgency: Medium - This is a low-value fine (€10,000) for a procedural breach, not involving substantive AML failures like suspicious transactions or sanctions screening delays seen in higher fines (e.g., €185,000 on Rakuten Bank). It matters as a precedent for CSSF's willingness to publicly name-and-shame for basic non-cooperation, potentially escalating to higher penalties for repeats; with publication on 9 January 2026, firms should prioritize 2025/2026 reporting to avoid similar exposure amid CSSF's active enforcement (3192+ sanctions published).

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

Topics:

Asset ManagerHedge Fund

🇱🇺 CSSF Enforcement medium

January 9th 2026

Administrative sanction of 11 September 2025

Administrative sanction imposed on the alternative investment fund manager C5 S.à r.l. (“AIFM”)

AI Analysis

The CSSF imposed a €10,000 administrative fine on alternative investment fund manager C5 Haven Cyber GP S.à r.l. on 11 September 2025 for failing to submit its annual financial crime questionnaire by the 4 April 2025 deadline, despite reminders, breaching the cooperation obligation under Article 5(1) of Luxembourg's AML/CFT Law of 12 November 2004. This enforcement action underscores CSSF's strict enforcement of reporting duties in AML/CFT compliance, serving as a warning to supervised entities on the consequences of administrative delays. It matters because it highlights low-tolerance for even minor procedural lapses, potentially signaling increased scrutiny on annual reporting amid broader AML/CFT priorities.

What Changed

This is not a regulatory change or new requirement but an enforcement of existing obligations under the amended AML/CFT Law:
Article 5(1) mandates supervised professionals, including AIFMs under Article 3(2) of the Law of 12 July 2013 on AIFMs, to cooperate fully with CSSF, including submitting the annual financial crime...
Breach occurred due to non-submission of the 2024 year-end Questionnaire, with fine determined per Articles 8-4(1), 8-4(2)(f), 8-4(3)(a), and 8-5(1).
Publication of the sanction follows Article 8-6(1), after proportionality assessment to avoid market stability risks. No new rules introduced; reinforces ongoing duty to meet CSSF reporting timelines...

Suggested Considerations

Review and confirm timely submission of all pending or future CSSF financial crime questionnaires; establish automated calendar reminders for annual deadlines (e.g., 4 April for prior year-end data).
Implement escalation protocols for CSSF reminders, ensuring immediate response and submission within days, not weeks.
Conduct internal audit of AML/CFT cooperation obligations, documenting justifications for any delays and preparing evidence for potential CSSF hearings or meetings.
Update compliance policies to prioritize Article 5(1) duties, including training for responsible persons on fine risks under Article 8-4.
For AIFMs: Verify alignment with Article 3(2) of AIFM Law and integrate questionnaire processes into governance frameworks.

Key Dates

AI Analysis

The AMF Enforcement Committee fined asset management company M Capital Partners €200,000 and its directors Rudy Secco (€70,000) and Stéphanie Minissier (€35,000) on 31 December 2025 for breaches of professional obligations spanning August 2019 to December 2023, including non-operational investment systems, deficient AML/CFT procedures, inadequate conflict of interest management, and poor due diligence traceability. This decision underscores AMF's focus on operational robustness in asset management, with personal liability for senior managers, signaling heightened enforcement risk for similar firms. Compliance teams must prioritize reviewing internal procedures to avoid comparable sanctions, as appeals are possible but do not suspend obligations.

What Changed

This is an enforcement action, not a new regulation, but it reinforces existing AMF requirements under the French Monetary and Financial Code for asset managers to maintain operational procedures.
Imprecise investment allocation processes lacking traceability, rendering systems non-operational.
Failure to fulfill conflict of interest identification, prevention, and management obligations.
Deficient AML/CFT systems with inadequate due diligence on fund assets/liabilities. These align with prior AMF expectations for "honest, fair, and professional" conduct with skill, care, and...

Suggested Considerations

Conduct immediate gap analysis of investment processes for operationality, traceability, and precision in allocation rules.
Enhance AML/CFT systems: Update risk mapping, procedures, and due diligence on fund assets/liabilities; ensure systematic application.
Review conflict of interest frameworks for identification, prevention, and management; document controls rigorously.
Senior managers: Demonstrate personal oversight via governance records to mitigate attribution of firm breaches.
Audit marketing materials, fee retrocessions, and valuation procedures (e.g., for real estate or experts) against AMF standards.

Key Dates

August 2019

December 2023; - Period of breaches investigated

31 December 2025

- AMF Enforcement Committee decision date imposing fines on M Capital Partners and directors

08 January 2026

- Public news release date for the decision

Compliance Impact

Urgency: High - This reflects a pattern of 2025-2026 AMF fines on asset managers for operational/AML failures (e.g., €1.3M on Altaroc 15 Sep 2025; €400k on Eternam 9 Sep 2025), indicating intensified scrutiny and personal accountability. Firms risk multimillion fines and reputational damage; immediate audits are essential pre-audit cycles, especially with appeals highlighting ongoing litigation risk.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

AML / Financial Crime Senior Managers / Governance Consumer Protection / Conduct

Topics:

Asset Manager

🇱🇺 CSSF Guidance high

January 8th 2026

Circular CSSF 26/904

Update of Circular CSSF 24/853 on the Long Form Report (as amended by Circular CSSF 25/870) – Practical rules concerning the self-assessment questionnaire to be submitted by investment firms Mission and related reports of the réviseurs d’entreprises agréés (approved statutory auditors)

AI Analysis

Circular CSSF 26/904 updates Circular CSSF 24/853 (as amended by Circular CSSF 25/870) by introducing a revised Long Form Report (LFR) for investment firms, featuring a digital self-assessment questionnaire (SAQ) and enhanced auditor reports focused on AML/CFT and risk management. This matters because it aligns reporting with CSSF's risk-based supervision under CSSF 4.0, reduces redundancies, applies proportionality based on business models, and mandates digital submission to improve efficiency and data analysis.

What Changed

- Revised LFR Structure: Comprises four parts in a single digital document: (1) yearly SAQ completed by investment firms; (2) descriptive elements verified by approved statutory auditors (REAs); (3)...
Digital Format: Completion and submission via CSSF's online portal, supporting CSSF 4.0 digital strategy for efficient processing.
Proportionality and Scope: Applies individually to investment firms (no consolidated LFR if under CSSF consolidated supervision); focuses on incremental, relevant information tied to business models,...
Enhanced AML/CFT Focus: Requires descriptions of commercial policy, ML/FT risk management, roles/responsibilities, branch/subsidiary/tied agent compliance; REA must assess adequacy of...
REA Responsibilities: Verify/ensure adequacy of SAQ elements, assess descriptions, perform control procedures, and provide assessments on AML/CFT policy implementation across entities.

Suggested Considerations

Investment Firms: Complete and submit the digital SAQ yearly via CSSF portal, providing descriptions of business model, ML/FT risks, commercial policy, monitoring, AML/CFT roles, and entity-level compliance; ensure data on fund transfers (e.g., missing payer/payee info) is included.
REAs/Auditors: Verify SAQ adequacy, assess descriptions, perform corroborative controls, supplement with findings (e.g., AML/CFT audit declarations), independently assess ML/FT risks/organization, and integrate into single LFR document.
General: Review existing processes for proportionality (focus on incremental info); update AML/CFT policies/documentation for branches/subsidiaries/tied agents; prepare for digital submission; document risk assessments thoroughly.
Ongoing: Monitor compliance with related regs like Regulation (EU) 2023/1113 (effective 30 December 2024, per draft bill 8387).

Key Dates

What Changed

- Immediate asset freeze: All assets of any kind held by the 37 listed persons (Nicolás Maduro and associates) in Switzerland must be frozen without delay; this targets individuals not previously...
Reporting obligation: Persons and institutions, including financial intermediaries, must report frozen assets or knowledge thereof to the Money Laundering Reporting Office Switzerland (MROS) per FIAA...
Duration: The freeze is valid for four years until 4 January 2030, unless revoked earlier.
Legal basis: Enacted under Article 3 FIAA as a "freeze for mutual legal assistance" post-political change, distinct from but additive to 2018 Venezuela sanctions under the Embargo Act.
Penalties: Non-compliance with freezing may result in up to three years' custody; reporting violations up to CHF 250,000 fine.

Suggested Considerations

Screen and identify: Immediately review client lists, accounts, and transactions against the ordinance annex listing 37 persons; use FINMA's ordinance publication and Classified Compilation of Federal Law.
Freeze assets: Block all assets (funds, securities, real estate, etc.) of listed persons; prevent any transfers, payments, or dealings.
Report to MROS: Notify MROS of frozen assets or relevant knowledge without delay, following FIAA protocols; include details on asset nature, value, and location.
Internal updates: Update compliance systems, screening tools, and PEP/ sanctions databases; train staff on FIAA obligations.
Document compliance: Maintain records of screening, freezes, and reports for potential FINMA audits; monitor for updates via FINMA and Federal Council releases.

Key Dates

What Changed

This is an enforcement decision, not a new regulation, but it reinforces existing requirements under AMF professional obligations for asset managers (sociétés de gestion), including:
Fully operational investment and divestment procedures that ensure traceability of compliance checks against fund policies and constraints.
Formalized due diligence prior to allocating investment projects to funds. No explicit changes to rules; instead, it clarifies enforcement expectations for procedure completeness and documentation,...

Suggested Considerations

Review and enhance investment/divestment procedures: Ensure completeness, traceability of all compliance checks (e.g., alignment with fund policies), and formalized pre-allocation due diligence; test for operationality via internal audits.
Document all processes rigorously: Maintain evidence of checks and due diligence to demonstrate skill, care, and diligence in line with authorization conditions.
Conduct gap analysis against AMF expectations: Cross-reference with similar cases (e.g., operational procedures, AML/CFT); remediate deficiencies promptly.
Senior manager training: Reinforce personal accountability for firm compliance; update governance frameworks.
Appeal monitoring: If similarly positioned, prepare for potential appeals to Conseil d’État.

Key Dates

10 December 2025 DEADLINE

- AMF Enforcement Committee decision date imposing fines; appeals possible (no specific deadline stated, but typically within 2 months to Conseil d’État)

Compliance Impact

Urgency: High – This decision, part of a 2025 enforcement wave fining asset managers €400k–€1.3m for procedural lapses (e.g., non-operational investment processes, inadequate due diligence), signals intensified AMF scrutiny on operational integrity. Firms risk personal fines for managers and reputational damage; immediate procedure audits are essential to mitigate exposure, especially pre-authorization renewals or fund launches.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

Reporting & Disclosure Senior Managers / Governance AML / Financial Crime

Topics:

Asset Manager

Banking & Credit Investment Management Wealth & Private Banking

🇨🇭 FINMA News medium

December 16th 2025

FINMA launches consultation on partially revised Circular 2016/7 “Video and online identification”

On 16 December 2025, the Swiss Financial Market Supervisory Authority FINMA launched the consultation on the partially revised Circular 2016/7 “Video and online identification”. The consultation will go on until 27 February 2026.

Deadline: 27 February 2026

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Authorisation & Licensing

BankWealth ManagerFintech

Banking & Credit Payments & E-Money Capital Markets & Trading

🇨🇭 FINMA Enforcement critical

December 15th 2025

Totalrevision der Verordnung über Massnahmen gegenüber der Islamischen Republik Iran

Der Bundesrat hat am 12. Dezember 2025 beschlossen, die Iran-Sanktionen dem Stand von vor dem Abschluss des Wiener Abkommens über das iranische Atomprogramm anzupassen. Dazu hat er die Verordnung über Massnahmen gegenüber der Islamischen Republik Iran einer Totalrevision unterzogen. Die neue Verordnung (SR 946.231.143.6) trat am 12. Dezember 2025 in Kraft.

AI Analysis

Switzerland has completely revised its Iran sanctions regulations effective December 12, 2025, restoring sanctions to pre-2015 levels following the automatic reinstatement of UN Security Council resolutions on September 28, 2025. This comprehensive overhaul requires Swiss financial institutions and businesses to immediately implement expanded asset freezes, trade restrictions, and sectoral prohibitions affecting Iran-related transactions and designated persons.

AI-generated analysis. May contain errors or omissions — verify with the original FINMA source before acting. Full disclaimer.

Sectors:

Topics:

AML / Financial Crime Reporting & Disclosure Operational Resilience / Outsourcing

BankPayment ProviderAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇨🇭 FINMA Enforcement critical

December 12th 2025

Sanktionen: Die Schweiz weitet ihre Sanktionslisten betreffend Russland und Belarus aus

Der Bundesrat hat die Sanktionslisten betreffend Russland und Belarus am 12. Dezember 2025 ausgeweitet. Die Schweiz übernimmt damit diverse Änderungen, welche die EU im Rahmen ihres 19. Sanktionspakets beschlossen hat.

AI Analysis

The Swiss Federal Council expanded sanctions lists against Russia and Belarus on December 12, 2025, adopting changes from the EU's 19th sanctions package to align Swiss measures with EU restrictions. This matters for Swiss financial institutions as it imposes immediate asset freezes, transaction bans, and reporting obligations on newly listed entities, strengthening efforts to counter Russia's military-industrial complex and shadow oil fleet while preventing sanctions evasion.

What Changed

- Asset freezes and prohibitions: 22 natural persons and 42 companies/organizations added to asset freeze and prohibition on making funds/assets available lists.
Shipping restrictions: 116 new vessels (primarily Russian shadow fleet tankers evading oil price caps) subjected to comprehensive purchase, sale, and service bans.
Export controls: 45 new companies (including in third countries) under stricter export controls to block deliveries of critical goods to Russia's military-industrial sector.
Financial transaction bans: Five Russian banks and four branches of Russian banks in third countries banned from transactions, especially those using Russian payment systems; eight third-country...

Suggested Considerations

Immediate screening: Review client lists, transactions, and assets against updated SECO sanctions lists (published by WBF) for matches to 22 persons, 42 entities, 116 vessels, 45 export-controlled firms, 5+4 banks, and 8 third-country firms.
Asset freezing: Block and freeze any matching assets/funds; prohibit making available.
Transaction halts: Cease dealings with listed banks, entities, vessels, or sanctioned goods/services.
Reporting: Notify SECO of frozen assets, blocked transactions, or existing business relationships immediately; conduct additional due diligence on suspicions per Art. (FINMA guidelines).
Ongoing monitoring: Update compliance systems for dynamic lists; train staff on shadow fleet risks and third-country evasion.

Key Dates

29 October 2025

Das Staatssekretariat für Wirtschaft (SECO) hat eine Änderung des Anhangs der Verordnung vom 7. August 1990 über Wirtschaftsmassnahmen gegenüber der Republik Irak (SR 946.206) publiziert.

AI Analysis

This FINMA publication announces a SECO update to the annex of the Ordinance on Economic Measures against the Republic of Iraq (SR 946.206), reflecting UN Sanctions Committee amendments to the list of sanctioned individuals, companies, and organizations made on December 9, 2025. It matters because these changes are directly applicable in Switzerland, requiring financial intermediaries to immediately block affected assets and report business relationships to SECO to ensure compliance with UN sanctions. Failure to act risks enforcement by FINMA under its supervisory mandate.

What Changed

- The UN Sanctions Committee modified the sanctions list targeting persons, companies, and organizations related to Iraq on December 9, 2025; this amendment was published by SECO on its website and...
Switzerland automatically applies UN sanctions lists without delay per the Federal Council's Ordinance of March 4, 2016, making the update immediately binding.
Financial intermediaries must implement prohibitions, freeze assets of newly listed or adjusted entities, and notify SECO of any impacted business relationships, consistent with prior Iraq sanctions...

Suggested Considerations

Screen against SESAM database: Immediately rescreen client portfolios, transactions, and business relationships against the updated Iraq sanctions list via SECO's SESAM tool (https://www.seco.admin.ch/sesam).
Asset freeze: Block and freeze any assets, funds, or economic resources belonging to newly sanctioned parties; do not dispose of or make available.
Report to SECO: Notify SECO of any matches or business relationships via the designated reporting channel within required timelines (typically immediate for freezes).
Internal review: Update compliance systems, screening tools, and policies; conduct targeted audits for Iraq/Middle East exposure; train staff on implementation.
Document compliance: Maintain records of screening, freezes, and reports for FINMA audits.

Key Dates

Immediate (as of December 10, 2025) DEADLINE

- Financial intermediaries must block assets and report to SECO without delay, per automatic application of UN sanctions

December 9, 2025

- UN Sanctions Committee decision amending the Iraq sanctions list

December 10, 2025

- SECO publishes update on its website and updates SESAM database; changes enter into force immediately in Switzerland

Compliance Impact

Urgency: High - Automatic and immediate effect heightens breach risk, with FINMA enforcement powers including fines, reputational damage, or license revocation for non-compliance. It matters due to Switzerland's direct implementation of UN sanctions, amplifying AML/financial crime exposure amid ongoing global sanctions volatility (e.g., Iraq-related terrorism financing risks).

References

AI-generated analysis. May contain errors or omissions — verify with the original FINMA source before acting. Full disclaimer.

Sectors:

Topics:

BankAsset ManagerWealth Manager

Banking & Credit Investment Management Capital Markets & Trading

🇺🇸 CFTC News medium

December 9th 2025

CFTC Obtains Over $2M Restitution for Victims of Precious Metals, Foreign Currency Pool Fraud

No description available.

Sectors:

Topics:

Consumer Protection / Conduct AML / Financial Crime Reporting & Disclosure

Broker DealerAsset ManagerBank

Banking & Credit Payments & E-Money Wealth & Private Banking

🇨🇭 FINMA Enforcement critical

December 9th 2025

Aktualisierte Sanktionsmeldung: Sudan

Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung (WBF) hat den Anhang 2 der Verordnung vom 25. Mai 2005 über Massnahmen gegenüber Sudan (SR 946.231.18) geändert.

AI Analysis

On December 9, 2025, Switzerland's State Secretariat for Economic Affairs (SECO) updated Annex 2 of the Sudan Sanctions Ordinance (SR 946.231.18), requiring Swiss financial intermediaries to implement changes to their sanctions screening and compliance procedures. This update reflects ongoing international coordination on Sudan sanctions enforcement and requires immediate implementation by all Swiss-regulated financial institutions.

What Changed

The regulatory update modified Annex 2 of the Sudan Sanctions Ordinance effective December 9, 2025 at 23:00 UTC. While the search results do not provide the specific entities added or removed from the sanctions list, the update was coordinated through FINMA's SESAM (SECO Sanctions Management) database, which serves as Switzerland's authoritative sanctions database for financial intermediaries. The timing of this update aligns with broader international sanctions activity on Sudan.

Suggested Considerations

*Sanctions List Update: Immediately download and integrate the updated SESAM sanctions database into all transaction screening systems and customer due diligence (CDD) procedures.
*System Screening: Conduct full rescreening of existing customer relationships, beneficial owners, and transaction counterparties against the updated Annex 2 designations.
*Transaction Review: Review all pending and recent transactions (typically 30-90 days prior) to identify any that may have involved newly designated persons or entities.
*Blocked Assets: If any blocked persons or entities are identified in existing customer relationships, immediately freeze accounts and file required reports with SECO.
*Staff Training: Update compliance and front-office staff on the specific changes to ensure proper application of the updated sanctions regime.

Key Dates

December 9, 2025, 23:00 UTC

- Effective date of the urgent amendment to Annex 2 of SR 946.231.18; SECO updated the SESAM database on this date

Immediate DEADLINE

- Financial intermediaries required to implement changes according to SR 946.231.18 regulations

Compliance Impact

Urgency: CRITICAL

References

AI-generated analysis. May contain errors or omissions — verify with the original FINMA source before acting. Full disclaimer.

Sectors:

Topics:

BankPayment ProviderWealth Manager

Banking & Credit Capital Markets & Trading Payments & E-Money

🇬🇧 BoE News

December 8th 2025

Minutes of the London FXJSC Legal Sub-committee Meeting – 17 September 2025

The Bank of England chairs the London Foreign Exchange Joint Standing Committee (FXJSC) Legal Sub-Committee. The FXJSC is made up of market participants, infrastructure providers and the UK financial regulators.

Sectors:

Topics:

AML / Financial Crime Market Abuse / Surveillance Reporting & Disclosure

BankBroker DealerFintech

Banking & Credit Investment Management Capital Markets & Trading

🇦🇪 ADGM News high

December 8th 2025

08 Dec 2025 Read more

Sectors:

Topics:

AML / Financial Crime Prudential / Capital Requirements Technology & Cyber

BankAsset ManagerBroker Dealer

Banking & Credit Investment Management Crypto & Digital Assets

🇺🇸 SEC News medium

December 5th 2025

SEC Announces Agenda and Panelists for Roundtable on Financial Surveillance and Privacy

The Securities and Exchange Commission’s Crypto Task Force has announced the agenda and panelists for its rescheduled Roundtable on Financial Surveillance and Privacy.“New technologies give us a fresh opportunity to recalibrate financial surveillance…

Sectors:

Topics:

AML / Financial Crime Technology & Cyber Market Abuse / Surveillance

BankBroker DealerCrypto Exchange

Investment Management Wealth & Private Banking

🇮🇪 CBI Warning high

December 5th 2025

Sanctions & settlements Anti-money Laundering Governance Investment advice Other professionals Journalists Investment services providers The AMF Enforcement Committee fines a financial investment advisor and its two directors a total of €2.5...

AI Analysis

The AMF Enforcement Committee fined financial investment advisor Carat GP €300,000 and its directors Jimmy Guinet (€200,000) and Sébastien Renaud (€2 million) a total of €2.5 million on 5 November 2025, imposing permanent bans on Carat GP and Renaud, and a 10-year ban on Guinet, for breaches including inadequate documentation, failure to act honestly and professionally in clients' interests, AML failures, lack of conflict detection systems, and insufficient cooperation with inspectors. This decision marks the first time the Committee held directors personally liable for breaches, signaling heightened personal accountability for senior managers in French investment firms. It matters as it reinforces AMF's focus on governance, AML, and client protection, with severe sanctions serving as a deterrent amid rising enforcement trends.

What Changed

This is an enforcement action, not a regulatory change, but it clarifies and strengthens application of existing AMF rules for conseillers en investissements financiers (CIFs) under French...
Mandatory compliant documentation (e.g., investment proposals).
Obligation to act honestly, fairly, and professionally in clients' best interests, including systems to prevent managers exploiting positions for undocumented investments.
AML/CFT compliance, including prohibitions on directors receiving client funds in personal accounts.
Annual training for directors and diligent cooperation with AMF inspections.

Suggested Considerations

Audit documentation: Ensure all investment advice is fully documented and compliant; implement traceability for proposals.
Strengthen governance: Deploy systems to detect/prevent conflicts, especially manager-led undocumented investments; enforce annual director training.
Enhance AML/CFT: Prohibit personal receipt of client funds; conduct KYC and transaction monitoring.
Improve inspection readiness: Train staff for diligent, honest cooperation with AMF; maintain secure archives.
Senior manager reviews: Assess personal compliance liabilities; update senior managers regime policies.

Key Dates

1 January 2019 to 30 June 2024

- Relevant period of breaches for Carat GP

5 November 2025

- AMF Enforcement Committee decision issued, imposing fines and bans

6 November 2025

- French version of press release published

Compliance Impact

Urgency: High - Recent (November 2025) decision with record €2.5m fines and novel personal director liability elevates risks for CIFs and managers, amid AMF's pattern of escalating sanctions on governance/AML failures (e.g., similar cases in 2019-2025). Firms must act promptly to avoid parallel enforcement, as breaches spanned years and AMF emphasizes educational deterrence through decisions.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

Topics:

AML / Financial Crime Senior Managers / Governance Consumer Protection / Conduct

Wealth ManagerAsset ManagerAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇨🇭 FINMA News medium

November 7th 2025

Aktualisierte Sanktionsmeldung: ISIL (Da'esh) / Al-Kaida

Sectors:

Topics:

AML / Financial Crime Prudential / Capital Requirements Reporting & Disclosure

BankWealth ManagerAll Firms

Payments & E-Money Crypto & Digital Assets

🇮🇪 CBI Enforcement high

November 6th 2025

The Central Bank takes enforcement action against Coinbase Europe Limited for anti-money laundering failures

The Central Bank of Ireland has fined Coinbase Europe Limited €21,464,734 for breaching its anti-money laundering and counter terrorist financing transaction monitoring obligations between 2021 and 2025. The Central Bank of Ireland (the Central Bank) has fined Coinbase Europe Limited (Coinbase Europe) €21,464,734 for breaching its anti-money laundering (AML) and combatting terrorist financing (CFT) obligations with respect to transaction monitoring as required by the Criminal Justice (Money L...

AI Analysis

The Central Bank of Ireland (CBI) fined Coinbase Europe Limited €21,464,734 for AML/CFT transaction monitoring failures under the Criminal Justice (Money Laundering and Terrorist Financing) Act 2010 (CJA 2010), involving over 30 million unmonitored transactions worth €176 billion from April 2021 to March 2025. This marks CBI's first enforcement against a crypto firm, highlighting regulators' focus on robust real-time monitoring and timely Suspicious Transaction Reporting (STR) for virtual asset service providers (VASPs). It matters as it sets a precedent for EU crypto compliance amid MiCA and AMLA implementation, signaling increased scrutiny and potential multimillion-euro penalties for similar lapses.

What Changed

This is an enforcement action, not new legislation, but it reinforces existing CJA 2010 requirements for VASPs: ongoing transaction monitoring, immediate STR filing to the Financial Intelligence Unit (FIU) and Revenue Commissioners upon suspicion of money laundering or terrorist financing, and adoption of internal policies/controls to prevent/detect financial crime.

Suggested Considerations

Conduct Gap Analysis: Review transaction monitoring systems for configuration errors, back-testing historical data, and ensuring 100% coverage of high-risk transactions.
Enhance Controls: Implement robust internal policies, automated alerts, and governance to detect/prevent ML/TF; test systems regularly for faults affecting >1% of volume.
Accelerate STR Processes: Ensure real-time suspicion flagging and filing; remediate delays via prioritized back-monitoring with FIU coordination.
Board/Compliance Reporting: Document remediation plans, as Coinbase did, and prepare for audits/enforcement; train staff on VASP-specific risks under MiCA/AMLA.
Third-Party Review: Engage independent auditors to validate fixes, mirroring Coinbase's post-error cooperation.

Key Dates

23 April 2021

19 March 2025; Period of breaches, including 12-month window of unmonitored €176 billion transactions

5 November 2025

Settlement reached between CBI and Coinbase Europe

6 November 2025

CBI public announcement and Settlement Notice published

12 January 2026

High Court confirmed sanctions, making them final and effective

Compliance Impact

Urgency: High – This establishes a €21.5m benchmark for VASP monitoring failures in the EU, with risks amplified by MiCA (effective 2024) and AMLA (2025 onward), where national regulators like CBI will enforce harmonized rules. Firms risk similar fines (30% settlement discount possible), reputational damage, and operational restrictions if unmonitored volumes exceed 1-5%; immediate reviews are essential given CBI's precedent and cross-EU applicability.

References

AI-generated analysis. May contain errors or omissions — verify with the original CBI source before acting. Full disclaimer.

Sectors:

Topics:

Crypto ExchangeFintechPayment Provider

Reporting & Disclosure AML / Financial Crime Prudential / Capital Requirements

🇱🇺 CSSF Guidance high

November 3rd 2025

Circular CSSF 25/897

Update of Circular CSSF 22/821 on the Long Form Report, as amended by Circulars CSSF 23/845 and CSSF 24/865

AI Analysis

Circular CSSF 25/897 updates Circular CSSF 22/821 on the Long Form Report (LFR) for credit institutions, further aligning the self-assessment questionnaire (SAQ) with current supervisory priorities such as ML/FT risks and organizational aspects. This matters because it refines reporting to reduce redundancies, enhance transparency in REA assessments, and reflect evolving prudential focuses since prior amendments via Circulars CSSF 23/845 and 24/865, ensuring institutions' reports better support CSSF oversight.

What Changed

- Introduces new modules in the revised SAQ to align with supervisory points of focus, building on prior expansions (e.g., credit/counterparty risk, liquidity risk, climate-related risks from CSSF...
Emphasizes REA's independent assessment in the AML/CFT report, requiring exhaustive, transparent evaluations of ML/FT risks across institutions, branches, majority-owned subsidiaries abroad, and tied...
REA must verify and amend descriptive elements provided by management for the Financial Instruments and Funds Report and AML/CFT report, including quantitative metrics like pending file ratios.
Confirms the three-part LFR framework: institution-completed SAQ, REA's client assets protection report (per Article 7 of Grand-ducal Regulation of 30 May 2018), and REA's AML/CFT report; no Agreed...
Enhances REA responsibilities for collateral arrangements and client fund protections under relevant laws.

Suggested Considerations

Complete and submit revised SAQ annually, incorporating new modules on supervisory focuses like ML/FT risks and providing detailed data to REA.
Authorized management: Supply accurate descriptive information to REA for reports, covering client protections, collateral, and AML/CFT procedures across group entities.
REA: Independently assess and report on ML/FT risks and client assets with transparency, quantitative details, and verified management inputs; avoid imprecise language.
Ensure AML/CFT report details methodologies (e.g., sampling techniques) and covers branches/subsidiaries/tied agents.
Review prior LFR submissions against this update to align with suppressed redundancies and new emphases.

Key Dates

31 October 2025

- Issuance date of Circular CSSF 25/897

Three months after financial year DEADLINE

end; - Annual submission deadline for SAQ to CSSF (unchanged from prior circulars)

Five months after financial year DEADLINE

end; - Submission deadline for REA Reports (Financial Instruments and Funds Report; AML/CFT Report)

Six months after financial year

end; - Aligned submission for REA management letter (per amendments in CSSF 23/845 to Circular 22/826)

Compliance Impact

Urgency: High - Institutions face immediate refinement needs for 2025 year-end reporting (e.g., SAQ due ~Q1 2026), with stricter REA scrutiny on AML/CFT transparency risking supervisory findings or enforcement if vague assessments persist; aligns with ongoing CSSF push for risk-focused oversight amid regulatory evolution.

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

Banking & Credit

Topics:

Bank

Banking & Credit Investment Management

🇱🇺 CSSF Guidance high

November 3rd 2025

Circular CSSF 22/821 (as amended by Circulars CSSF 24/865, CSSF 23/845 and CSSF 25/897) (Updated)

Long Form ReportPractical rules concerning the self-assessment questionnaire to be submitted by institutionsMission and related reports of the statutory auditors (réviseurs d’entreprises agréés)

AI Analysis

**Circular CSSF 22/821** (as amended) fundamentally restructures how Luxembourg credit institutions report to the Commission de Surveillance du Secteur Financier (CSSF) by replacing the traditional Long Form Report with a digital **self-assessment questionnaire (SAQ)**, complemented by auditor-prepared reports. This shift represents a significant operational change that requires institutions to directly participate in prudential self-assessment while maintaining robust external audit oversight, making it essential for compliance and operational teams to understand new submission requirements and digital workflows.

What Changed

The circular introduces a three-component reporting framework that fundamentally alters the compliance landscape:
Self-Assessment Questionnaire (SAQ): A digital, annually-completed questionnaire that institutions must prepare directly, covering domains within CSSF and ECB prudential supervision competence
Agreed Upon Procedures (AUP) Reports: Reports prepared by approved statutory auditors (réviseurs d'entreprises agréés) on specific compliance areas
Separate REA Report on Financial Instruments Protection: A dedicated auditor assessment on safeguarding of client financial instruments Scope of SAQ Coverage: The questionnaire addresses prudential...

Suggested Considerations

*For Credit Institutions:
*Establish SAQ Governance: Designate authorized management responsible for reviewing and electronically signing the SAQ before submission; ensure accuracy and true-and-fair representation of information
*Data Preparation: Align SAQ responses with prudential reporting figures (FINREP/COREP/LAREX) under IFRS as of financial year closure
*Digital System Access: Obtain access credentials to the CSSF digital solution and familiarize compliance teams with the platform interface and submission workflow
*Module Completion: Complete all applicable SAQ modules as configured in the CSSF digital solution; note that module applicability and exemptions are institution-specific and recorded directly in the system

Key Dates

25 October 2022

- Circular CSSF 22/821 issued

23 December 2022

- Initial publication date (updated 15 November 2023)

31 December 2022

- Circular enters into application

Three months before financial year closure

- SAQ becomes accessible through CSSF digital solution

Three months after financial year closure DEADLINE

- Deadline for SAQ submission to CSSF

Compliance Impact

Urgency: HIGH

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

Topics:

Prudential / Capital Requirements AML / Financial Crime Reporting & Disclosure

Bank

Banking & Credit Payments & E-Money Capital Markets & Trading

🇨🇭 FINMA Enforcement high

October 31st 2025

Aktualisierte Sanktionsmeldung: Belarus

Die Schweiz schliesst sich den weiteren Massnahmen des 18. Sanktionspakets der Europäischen Union (EU) gegenüber Russland sowie den zusätzlich zum 18. Sanktionspaket erlassenen Massnahmen gegenüber Belarus an. Dies hat der Bundesrat am 29. Oktober 2025 beschlossen. Im Fokus stehen Massnahmen im Güter-, Finanz und Energiebereich. Der Bundesrat hat dafür die Verordnung über Massnahmen gegenüber Belarus (SR 946.231.116.9) geändert.

AI Analysis

Switzerland has aligned with additional EU measures from the 18th sanctions package against Russia and specific Belarus measures, amending the Ordinance on Measures against Belarus (SR 946.231.116.9) to focus on goods, financial, and energy sectors. This strengthens the sanctions regime against Belarus to mirror Russia's more closely, aiming to enhance effectiveness and prevent circumvention. Compliance teams must prioritize asset freezes, transaction prohibitions, and reporting to avoid enforcement risks from FINMA and SECO.

What Changed

- Alignment with EU's 18th sanctions package (adopted 18 July 2025) and additional Belarus-specific measures, targeting Belarus's involvement in Russia's war against Ukraine.
Amendments to SR 946.231.116.9, harmonizing Belarus sanctions with Russia's regime, particularly in goods (e.g., export restrictions on chemicals, metals, plastics for military/tech strengthening),...
Requirements for financial intermediaries to implement prohibitions, freeze assets of sanctioned persons, and report affected business relationships to SECO (State Secretariat for Economic Affairs).
Reporting to SECO does not exempt intermediaries from AML due diligence under Art. 6 GwG (Anti-Money Laundering Act) or suspicious activity reports under Art.

Suggested Considerations

Immediately screen client portfolios, transactions, and assets against updated SECO sanctions lists for Belarus (and cross-reference Russia lists).
Freeze assets of newly sanctioned persons/entities and prohibit dealings (e.g., no transactions with listed banks, no exports of restricted goods).
Report all affected business relationships to SECO promptly; conduct parallel GwG AML checks and file SARs if suspicions persist.
Update compliance systems, transaction monitoring rules, and staff training for goods/financial/energy sanctions; cease any prohibited services (e.g., SWIFT-like messaging for listed banks).
Review third-party exposures (e.g., Drittländer firms) for evasion risks and document compliance efforts for FINMA audits.

Key Dates

18 July 2025

- EU adopts 18th sanctions package against Russia and additional Belarus measures

29 October 2025

- Swiss Federal Council decides to align and amends SR 946.231.116.9

30 October 2025

- New provisions enter into force

13 December 2025

- Related expansion of Russia/Belarus lists (22 persons, 42 entities, 116 ships, 45 trade firms) takes effect, relevant for harmonization context

Compliance Impact

Urgency: High - Effective 30 October 2025, these changes demand immediate portfolio screening and reporting, with non-compliance risking FINMA enforcement, asset seizure, or criminal penalties under sanctions laws. Matters due to rapid alignment with evolving EU packages, increasing circumvention risks via Belarus, and heightened FINMA scrutiny on financial intermediaries amid ongoing Russia/Ukraine conflict.

References

AI-generated analysis. May contain errors or omissions — verify with the original FINMA source before acting. Full disclaimer.

Sectors:

Topics:

AML / Financial Crime Reporting & Disclosure Authorisation & Licensing

BankPayment ProviderAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇨🇭 FINMA Enforcement critical

October 30th 2025

Aktualisierte Sanktionsmeldung: Russland

AI Analysis

On October 29, 2025, the Swiss Federal Council (Bundesrat) adopted comprehensive sanctions measures aligned with the EU's 18th sanctions package against Russia and additional measures against Belarus, effective October 30, 2025. This enforcement action significantly expands financial transaction prohibitions, export restrictions, and asset freezes, requiring Swiss financial intermediaries to immediately implement new compliance obligations across banking, goods trade, and energy sectors.

What Changed

Financial Sector Restrictions The Bundesrat expanded transaction prohibitions on Russian banks substantially:
Extended existing transaction bans from 23 Russian banks to cover all specialized payment messaging services, converting these to complete transaction prohibitions
Introduced new transaction prohibitions for 22 additional Russian banks
Prohibited all transactions with the Russian Direct Investment Fund (RDIF), its sub-funds, and affiliated enterprises, tightening restrictions previously limited to RDIF-financed projects Export...
Chemical components for fuel production

Suggested Considerations

*Implement transaction prohibitions on all 45+ Russian banks now subject to complete bans (previously 23 with partial restrictions)
*Freeze assets of all sanctioned persons and entities immediately upon notice
*Report affected business relationships to SECO—this reporting obligation does not relieve firms from conducting additional due diligence when suspicious indicators exist
*Screen counterparties against updated sanctions lists, particularly the RDIF and its sub-funds
*Cease all transactions with newly prohibited entities, including payment system operators and financial institutions in third countries (Belarus, Kazakhstan) supporting Russian war economy

Key Dates

Topics:

AML / Financial Crime Prudential / Capital Requirements Reporting & Disclosure

BankWealth ManagerAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇨🇭 FINMA Enforcement high

October 21st 2025

Aktualisierte Sanktionsmeldung: Haiti

Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung des Anhangs der Verordnung vom 16. Dezember 2022 über Massnahmen betreffend Haiti publiziert.

AI Analysis

The Swiss Federal Department of Economic Affairs, Education and Research (WBF, under which SECO operates) has published an update to the Annex of the Ordinance of 16 December 2022 on measures concerning Haiti, reflecting UN Security Council amendments to the sanctions list. This matters for Swiss financial institutions as it triggers immediate asset freeze checks and reporting obligations to ensure compliance with Switzerland's implementation of UN sanctions via FINMA and SECO oversight, avoiding enforcement risks amid Haiti's ongoing instability. The update aligns with global renewals of Haiti sanctions, emphasizing asset freezes on newly designated individuals and entities involved in destabilizing activities.

What Changed

- Amendment to the Annex of the Verordnung vom 16. Dezember 2022 über Massnahmen betreffend Haiti, incorporating UN Security Council updates to the sanctions list, likely adding individuals,...
Reflects broader UN measures, including renewal of travel bans, asset freezes, and arms embargoes; expansion of arms embargo scope to military goods, technology, technical assistance, financial...
Switzerland implements via SECO's sanction ordinances, with FINMA enforcing for supervised entities; parallels international updates like UN Resolution 2752 (2024) and 2794 (2025), which reintroduce...

Suggested Considerations

Screening and Freezing: Immediately review client databases, accounts, and holdings against the updated SECO Haiti sanctions list; freeze funds/economic resources of designated persons/entities without notice or delay; do not deal with or make available such assets indirectly.
Reporting: Notify SECO (via ams@seco.admin.ch or portal) and FINMA of matches, providing details on frozen assets; report any additional compliance-facilitating information.
Ongoing Monitoring: Update transaction screening systems for expanded arms embargo prohibitions (e.g., no financial services for military goods/technology to Haiti-connected persons); cease brokering or technical assistance if applicable.
Licensing Checks: Refrain from activities unless licensed by competent authorities (e.g., SECO for exemptions).
Documentation: Maintain records of checks and actions for audits; train staff on updated definitions (e.g., "military goods," "connected with Haiti").

Key Dates

18 October 2024

- UN Security Council Resolution 2752 adopted, expanding arms embargo (basis for Swiss/UK updates)

20 March 2025

- Canadian amendments add 3 individuals (related context)

Immediate (publication date: 21 October 2025) DEADLINE

- Swiss firms must check accounts, freeze assets or economic resources of newly listed persons without prior notice, and report to SECO/FINMA without delay

23 July 2025

- UK Haiti Sanctions Amendment Regulations enter force, reflecting similar UN changes

20 October 2025; - UNSC renews regime for one year, adds 2 entries to sanctions list (UK/Jersey notices align with Swiss publication)

Compliance Impact

Urgency: High - Immediate asset freeze and reporting requirements carry criminal penalties for non-compliance (e.g., aligned with UK fines up to updated monetary levels); failure risks FINMA enforcement, reputational damage, and misalignment with UN obligations amid Haiti's volatile security. Matters due to expanded scope capturing indirect financial facilitation, increasing false positive screening burdens for firms with Haiti exposure.

References

AI-generated analysis. May contain errors or omissions — verify with the original FINMA source before acting. Full disclaimer.

Sectors:

Topics:

BankWealth ManagerAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇨🇭 FINMA Enforcement high

October 21st 2025

Aktualisierte Sanktionsmeldung: Nicaragua

Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung des Anhangs der Verordnung vom 24. Juni 2020 über Massnahmen gegenüber Nicaragua (SR 946.231.158.5) publiziert.

AI Analysis

The Swiss Federal Department of Economic Affairs, Education and Research (WBF/EAER) amended the annex of the Ordinance on Measures against Nicaragua (SR 946.231.158.5) on 20 October 2025, modifying entries for two individuals, with measures entering into force immediately thereafter. This update requires Swiss financial intermediaries to promptly screen and adjust sanctions compliance programs to reflect the revised designations, ensuring no prohibited dealings with the updated list. It matters because failure to implement could trigger FINMA enforcement, asset blocking obligations, and reporting requirements under Switzerland's Embargo Act (EmbG).

What Changed

- Modification of entries for two individuals in the annex of the Ordinance on Measures against Nicaragua (SR 946.231.158.5), likely involving updates to personal details, aliases, or sanction...
These changes align with ongoing maintenance of the sanctions list, originally imposed in June 2020 due to human rights, democracy, and rule-of-law concerns in Nicaragua, mirroring EU measures from...
No broader structural changes to the ordinance itself; this is a targeted annex update, similar to frequent "delta" amendments published by SECO.

Suggested Considerations

Block and report: Freeze any newly or modifiedly sanctioned assets; report to FINMA/SECO via MyFINMA if matches found.
Update compliance systems: Integrate the annex changes into screening tools, policies, and training; conduct risk assessments for Nicaragua exposure.
Monitor ongoing: Subscribe to FINMA news (https://www.finma.ch/en/news/) and SECO updates for further deltas.
Document implementation to demonstrate due diligence in case of FINMA audits.

Key Dates

20 October 2025

- Amendment to the annex published by WBF/EAER

21 October 2025

- FINMA publishes updated sanctions notice and notifies via MyFINMA

21 October 2025, 11:00 pm

- Measures enter into force; immediate blocking and screening obligations apply

Compliance Impact

Urgency: High – Immediate effect from 21 October 2025 demands swift action to avoid violations, as asset freezing is retroactive and non-compliance risks FINMA enforcement (e.g., fines, license restrictions). This matters amid frequent 2025 sanctions updates (e.g., 10+ Nicaragua/Myanmar deltas), heightening operational burden and geopolitical risk exposure in FINMA's 2025 Risk Monitor.

References

AI-generated analysis. May contain errors or omissions — verify with the original FINMA source before acting. Full disclaimer.

Sectors:

Topics:

BankAsset ManagerWealth Manager

Banking & Credit Investment Management Payments & E-Money

🇨🇭 FINMA Enforcement high

October 21st 2025

Aktualisierte Sanktionsmeldung: Islamischen Republik Iran

Am 20. Oktober 2025 hat das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF die Liste der in diesem Kontext sanktionierten Personen, Unternehmen und Organisationen geändert. Das WBF hat die für die Schweiz massgebliche Sanktionsdatenbank SESAM (SECO Sanctions Management) angepasst und die Anpassung auf seiner Internetseite dringlich veröffentlicht. Die Änderung tritt am 21. Oktober 2025 23:00 Uhr in Kraft. Die Finanzintermediäre werden gemäss den Vorschriften der Verordnu...

AI Analysis

This FINMA publication notifies Swiss financial intermediaries of updates to the Swiss sanctions list against the Islamic Republic of Iran, as amended by the Federal Department of Economic Affairs, Education and Research (WBF) on October 20, 2025, via the SESAM sanctions database. It matters because financial firms must immediately screen clients, freeze assets, and report matches to comply with Swiss sanction ordinances, amid escalating global Iran sanctions following UN snapback mechanisms. Failure to act risks enforcement by FINMA or SECO.

What Changed

The core change is the WBF's amendment to the SESAM (SECO Sanctions Management) database, updating the list of sanctioned persons, companies, and organizations related to Iran sanctions. This aligns with the Swiss Iran Ordinance and reflects broader international reimposition of UN sanctions via the JCPOA snapback mechanism triggered in late September 2025. No new Swiss-specific requirements are introduced beyond standard implementation of the updated list, but it emphasizes urgent publication and binding effect under existing ordinances.

Suggested Considerations

Immediate screening: Run full client and transaction screening against updated SESAM list via SECO's website or integrated tools.
Asset freeze: Block any funds, assets, or economic resources of newly listed parties without delay; report freezes to SECO within specified timelines (typically 30 days).
Transaction blocks and reporting: Halt prohibited dealings; file suspicious activity reports (SARs) to Money Laundering Reporting Office Switzerland (MROS) if Iran exposure suspected.
Due diligence enhancement: Review existing Iran-related exposures, especially shadow banking, oil/petroleum networks, or IRGC-linked entities; update risk assessments.
Internal controls: Ensure automated screening tools are synced with SESAM by effective date; train staff on updates.

Key Dates

21 October 2025, 23:00 Uhr

- Changes enter into force, binding on all Swiss financial intermediaries

29 September 2025

- Triggering UN snapback sanctions on Iran reinstated (contextual lead-in). https://www.mrllp.com/news-item/monthly-sanctions-update-october-2025/

20 October 2025

- WBF amends SESAM database and publishes urgent update on its website

12 December 2025

- Swiss Federal Council expands Iran Ordinance, adding humanitarian exceptions and authorization grounds. https://sanctionsnews.bakermckenzie.com/swiss-government-significantly-expands-sanctions-against-iran/

Compliance Impact

Urgency: High - Effective immediately (post-21 Oct 2025), with today's date (Jan 2026) indicating firms had ~3 months to implement but must verify ongoing compliance amid further expansions (e.g., Dec 2025). Matters due to FINMA's strict enforcement history on sanctions (e.g., independent freezing measures), potential fines up to CHF 500k+, reputational risk, and alignment with global escalation (UN/UK/US/EU actions adding 100s of designations). Non-compliance exposes firms to audits, license risks.

References

AI-generated analysis. May contain errors or omissions — verify with the original FINMA source before acting. Full disclaimer.

Sectors:

Topics:

BankAll Firms

Banking & Credit Wealth & Private Banking

🇮🇪 CBI Warning high

October 20th 2025

Deutsche Bank Wealth Management (CLONE) / Deutsche Bank AG (CLONE) / DB UK Bank Limited (CLONE) - Central Bank of Ireland Issues Warning on Unauthorised Firm

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Authorisation & Licensing

BankWealth Manager

Banking & Credit Investment Management Wealth & Private Banking

🇨🇭 FINMA News medium

October 17th 2025

Aktualisierte Sanktionsmeldung: ISIL (Da'esh) / Al-Kaida

Sectors:

Topics:

AML / Financial Crime Prudential / Capital Requirements Reporting & Disclosure

BankWealth ManagerAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇬🇧 BoE Speech

October 14th 2025

Diversion ahead − speech by Alan Taylor

Given at King’s College, Cambridge

Sectors:

Topics:

AML / Financial Crime Prudential / Capital Requirements Operational Resilience / Outsourcing

BankWealth ManagerAsset Manager

Banking & Credit Investment Management Wealth & Private Banking

🇨🇭 FINMA News medium

October 10th 2025

Aktualisierte Sanktionsmeldung: ISIL (Da'esh) / Al-Kaida

Sectors:

Topics:

AML / Financial Crime Prudential / Capital Requirements Reporting & Disclosure

BankWealth ManagerAll Firms

Banking & Credit Capital Markets & Trading Payments & E-Money

🇬🇧 BoE News

October 8th 2025

Minutes of the London FXJSC Legal Sub-Committee Meeting - 24 June 2025

Sectors:

Topics:

AML / Financial Crime Market Abuse / Surveillance Reporting & Disclosure

BankBroker DealerFintech

Banking & Credit Investment Management Wealth & Private Banking

🇨🇭 FINMA Enforcement high

October 7th 2025

Aktualisierte Sanktionsmeldung: Burundi

Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung des Anhangs der Verordnung über Massnahmen gegenüber Burundi (SR 946.231.121.8) publiziert.

AI Analysis

The Swiss Federal Department of Economic Affairs, Education and Research (WBF/DEFR) has updated the annex to the Ordinance on Measures against Burundi (SR 946.231.121.8), modifying the list of sanctioned persons, companies, and organizations in the SESAM database. This matters for Swiss financial institutions as it imposes immediate asset freeze and transaction restrictions, aligning with FINMA's heightened focus on sanctions risks amid geopolitical tensions.

What Changed

- Modification to the list of sanctioned individuals, enterprises, and organizations under the Burundi sanctions ordinance.
Update published in the SECO Sanctions Management (SESAM) database, which is the authoritative Swiss reference for sanctions compliance.
No details on specific additions, deletions, or alterations to designations are provided in the publication summary, but changes trigger mandatory screening and blocking obligations.

Suggested Considerations

Screen clients, transactions, and assets against the updated SESAM database immediately upon effectiveness (post-8 October 2025, 23:00).
Freeze assets of newly listed or modified sanctioned parties without prior notice and report to SECO/FINMA via MyFINMA notification system.
Cease any direct or indirect provision of funds/economic resources to sanctioned parties; conduct retrospective reviews of existing relationships for Burundi exposure.
Update internal sanctions screening tools, policies, and staff training to reflect SESAM changes; document compliance efforts for potential FINMA audits.

Key Dates

8 October 2025, 23:00 hours

- Changes enter into force; asset freezes and prohibitions apply immediately thereafter

6 October 2025

- DEFR modifies the sanctions list and updates SESAM database

Compliance Impact

Urgency: High - Immediate effectiveness (8 October 2025) requires swift database rescreening to avoid violations, with FINMA emphasizing sanctions evasion risks in its 2025 Risk Monitor amid geopolitical shifts; non-compliance risks enforcement actions, fines, or reputational damage.

References

AI-generated analysis. May contain errors or omissions — verify with the original FINMA source before acting. Full disclaimer.

Sectors:

Topics:

BankAsset ManagerWealth Manager

Banking & Credit Investment Management Wealth & Private Banking

🇨🇭 FINMA Enforcement high

October 7th 2025

Sanktionsmeldung: Guinea-Bissau

Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung (WBF) hat eine Änderung des Anhangs 1 der Verordnung vom 1. Juni 2012 über Massnahmen gegenüber Guinea-Bissau (SR 946.231.138.3) publiziert.

AI Analysis

The Swiss Federal Department of Economic Affairs, Education and Research (WBF) published an amendment to Annex 1 of the Ordinance on Measures against Guinea-Bissau (SR 946.231.138.3) on October 7, 2025, updating the sanctions list maintained in the SESAM database. This change, effective October 8, 2025, requires Swiss financial intermediaries to immediately screen clients, freeze assets of listed individuals, and report to SECO, reinforcing compliance with UN Security Council Resolution 2048 (2012) and EU measures following the 2012 military coup. It matters for preventing sanctions evasion and ensuring adherence to Switzerland's Embargogesetz (EmbG), with non-compliance risking FINMA enforcement.

What Changed

- Amendment to Annex 1 of the Ordinance dated June 1, 2012, on measures against Guinea-Bissau, as published by WBF on October 6, 2025, and reflected in FINMA's announcement on October 7, 2025.
Updates to the SESAM (SECO Sanctions Management) database, which is the authoritative Swiss sanctions list; specific details on additions, deletions, or modifications to listed natural persons (e.g.,...
Prohibition on dealings with listed persons/entities; mandatory asset freeze and reporting obligations under the ordinance and Geldwäschereigesetz (GwG).

Suggested Considerations

Screen customer relationships against the updated SESAM list immediately upon effectiveness using heightened due diligence per GwG Art. 6.
Freeze assets of any matched listed persons/entities and prohibit new business.
Report affected relationships to SECO without delay; conduct additional checks and file SARs with MROS if suspicions remain.
Update internal sanctions screening systems and monitor MyFINMA for FINMA notifications.
Document compliance actions to demonstrate adherence in audits or FINMA inquiries.

Key Dates

October 8, 2025, 23:00 Uhr DEADLINE

- Changes enter into force; immediate implementation required for asset freezes and prohibitions

October 6, 2025

- WBF adjusts SESAM database and publishes changes on its website

October 7, 2025

- FINMA publishes the sanctions notice

Compliance Impact

Urgency: High - Immediate asset freeze and reporting are mandatory from October 8, 2025, with violations exposing firms to FINMA fines, reputational damage, or criminal liability under EmbG and GwG. This update underscores ongoing list volatility (e.g., similar 2024 change), demanding robust real-time screening to avoid inadvertent breaches in low-volume Guinea-Bissau exposures.

References

AI-generated analysis. May contain errors or omissions — verify with the original FINMA source before acting. Full disclaimer.

Sectors:

Topics:

BankWealth ManagerAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇨🇭 FINMA Enforcement high

October 7th 2025

Aktualisierte Sanktionsmeldung: Syrien

Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung des Anhangs 7 der Verordnung vom 8. Juni 2012 über Massnahmen gegenüber Syrien (SR 946.231.172.7) publiziert.

AI Analysis

The Swiss Federal Department of Economic Affairs, Education and Research (WBF) updated Annex 7 of the Ordinance on Measures against Syria (SR 946.231.172.7) on October 6, 2025, modifying the list of sanctioned persons, companies, and organizations, effective October 8, 2025. This change requires Swiss financial intermediaries to immediately implement asset freezes and report affected relationships to SECO, amid broader Swiss alignment with EU and US easing of Syria sanctions earlier in 2025. It matters for compliance as it mandates swift screening updates to avoid violations of ongoing targeted financial sanctions.

What Changed

- The WBF amended the list of sanctioned entities in Annex 7 of SR 946.231.172.7, updating the SESAM sanctions database (SECO Sanctions Management).
Financial intermediaries must enforce prohibitions, freeze assets of listed parties, and report business relationships to SECO.
Reporting to SECO does not exempt intermediaries from conducting due diligence under Art. 6 GwG (Anti-Money Laundering Act) and filing suspicions with the Money Laundering Reporting Office under Art.

Suggested Considerations

Screen client portfolios, accounts, and transactions against the updated SESAM database immediately upon effectiveness.
Freeze assets of newly listed or affected sanctioned parties and implement transaction prohibitions.
Report all impacted business relationships to SECO promptly.
Conduct GwG due diligence (Art. 6) on any suspicions; file with Money Laundering Reporting Office (Art. 9 GwG) if unresolved.
Update internal sanctions screening systems and train staff on changes; retain evidence of compliance for audits.

Key Dates

October 8, 2025 at 23:00

- Changes enter into force; asset freezes and prohibitions apply immediately

October 6, 2025

- WBF publishes update to Annex 7 and SESAM database

Compliance Impact

Urgency: High - Immediate asset freeze and reporting obligations take effect October 8, 2025, with non-compliance risking FINMA enforcement, fines, or criminal liability under sanctions laws. This matters as it occurs against a backdrop of Syria sanctions easing (e.g., Swiss economic sanctions lifted June 20, 2025; EU measures May 27, 2025), heightening risk of oversight on residual targeted lists amid increased Syria-related flows.

References

AI-generated analysis. May contain errors or omissions — verify with the original FINMA source before acting. Full disclaimer.

Sectors:

Topics:

BankWealth ManagerAll Firms

Crypto & Digital Assets Capital Markets & Trading Consumer Credit

🇦🇪 DFSA News

October 1st 2025

Notice of Consultation Paper Release: CP 168

01 OCT 2025, 09:38 AM Notice of Consultation Paper Release: CP 168

Sectors:

Topics:

AML / Financial Crime Prudential / Capital Requirements Reporting & Disclosure

Crypto ExchangeFintechAll Firms

Banking & Credit Payments & E-Money Capital Markets & Trading

🇨🇭 FINMA Enforcement critical

October 1st 2025

Aktualisierte Sanktionsmeldung: Russland

AI Analysis

The publication announces updates by the Swiss Federal Department for Economic Affairs, Education and Research (WBF) to Annex 8 of the Ordinance on Measures in Connection with the Situation in Ukraine (SR 946.231.176.72), aligning Swiss sanctions against Russia with ongoing international restrictions. This matters for Swiss financial intermediaries as it imposes immediate obligations to block assets, report relationships, and conduct AML checks, amid escalating sanctions that heighten compliance risks and enforcement scrutiny from FINMA.

What Changed

- Amendments to Annexes 8, 14, 15b, and 33 of the Ordinance, though specific details on new listings or prohibitions are not detailed in the announcement.
Continuation of standard requirements: Implement prohibitions, freeze assets of sanctioned persons, and report affected business relationships to SECO (State Secretariat for Economic Affairs).
These updates follow a pattern of prior changes, such as expanded export bans on dual-use goods (e.g., chrome ore, chemicals), transaction bans on additional Russian banks, and prohibitions on...

Suggested Considerations

Screen and freeze assets: Immediately identify and block assets of newly sanctioned persons/entities per updated annexes; do not release without authorization.
Report to SECO: Notify SECO of all affected business relationships without delay.
Conduct AML due diligence: Perform additional clarifications under Art. 6 GwG (Anti-Money Laundering Act) on suspicions; file suspicious activity reports (SARs) with the Money Laundering Reporting Office Switzerland (MROS) under Art. 9 GwG if unresolved—SECO reporting does not substitute this.
Review transactions: Halt prohibited activities (e.g., payments to/from listed banks, exports of controlled goods, RDIF investments); update screening tools and client onboarding processes.
Document compliance: Maintain records of screenings, blocks, and reports for FINMA audits.

Compliance Impact

Urgency: Critical – Effective immediately at 23:00 on January 13, 2026, with no grace period, this demands urgent system updates, screenings, and reporting to avoid FINMA enforcement (e.g., fines, licenses at risk). It amplifies AML / Financial Crime risks in a high-scrutiny environment, as FINMA's Risikomonitor 2025 highlights Russia sanctions as a top concern amid iterative updates.

References

AI-generated analysis. May contain errors or omissions — verify with the original FINMA source before acting. Full disclaimer.

Sectors:

Topics:

BankPayment ProviderAll Firms

🇫🇷 AMF Enforcement high

September 23rd 2025

The AMF Enforcement Committee fines an asset management company and its two managers a total of €1.3 million

Sanctions & settlements professional obligations Journalists Listed companies and issuers The AMF Enforcement Committee fines an asset management company and its two managers a total of €1.3 million

AI Analysis

The AMF Enforcement Committee fined asset management company Altaroc Partners €600,000 and its senior managers Maurice Tchenio (€500,000) and Patrick de Giovanni (€200,000) a total of €1.3 million on 15 September 2025 for breaches of professional obligations, including non-operational investment procedures, inadequate AML/CFT due diligence, deficient marketing materials, and unproven benefits from fee retrocessions to distributors. This decision underscores the AMF's heightened scrutiny on operational controls and senior accountability in asset management, serving as a critical enforcement signal for firms to strengthen procedures amid a pattern of similar sanctions.

What Changed

This is an enforcement action rather than new legislation, but it reinforces and clarifies existing professional obligations under AMF regulations for asset managers (sociétés de gestion),...
Operational investment/divestment procedures: Must be fully implemented, with traceability of checks on lender authorizations and compliance with fund policies.
AML/CFT due diligence: Systematic verification required on fund assets and liabilities; non-operational procedures or risk mapping constitute breaches.
Marketing and fee retrocessions: Materials must be accurate; firms must prove retrocessions enhance client service quality.
Senior manager accountability: Breaches attributable to responsible managers, emphasizing personal liability for oversight failures. No explicit regulatory changes, but the decision aligns with AMF's...

Suggested Considerations

Audit procedures immediately: Review and document operational status of investment/divestment processes, ensuring traceability of lender checks, fund policy compliance, and AML/CFT due diligence on assets/liabilities.
Enhance AML/CFT systems: Formalize risk mapping, procedures, and systematic investor/transaction due diligence; test for operational effectiveness.
Validate marketing and fees: Audit fund materials for accuracy; gather evidence that fee retrocessions to distributors improve client services (e.g., via service level agreements or performance metrics).
Senior manager training: Conduct gap analysis on personal accountability; update governance frameworks to mitigate attribution of firm breaches.
Mock AMF inspections: Simulate Enforcement Committee reviews, focusing on procedure formalization, independent valuers (if applicable), and conflict systems.

Key Dates

15 September 2025

- AMF Enforcement Committee decision issued, imposing fines on Altaroc Partners, Maurice Tchenio, and Patrick de Giovanni

16 September 2025

- French version of press release published

Post

15 September 2025 (exact date unspecified); - Appeal lodged by Altaroc Partners, Tchenio, and de Giovanni before the Conseil d’État against decision SAN-2025-09

Compliance Impact

Urgency: High – This fits a 2025 enforcement trend targeting asset managers' operational deficiencies (e.g., similar fines against Novaxia Investissement on 10 December 2025, M Capital Partners on 31 December 2025, and Eternam on 9 September 2025), signaling AMF's zero-tolerance for non-operational controls and AML gaps amid EU AIFMD reviews. Non-compliance risks personal fines up to €500,000+ for managers, reputational damage, and authorization challenges; proactive remediation is essential as appeals (like this one) do not suspend obligations.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

AML / Financial Crime Senior Managers / Governance Reporting & Disclosure

Topics:

Asset Manager

Banking & Credit Investment Management Wealth & Private Banking

🇫🇷 AMF Warning high

September 22nd 2025

The Autorité des marchés financiers (AMF) is warning professionals about the extensive fraudulent and malicious use of its name engaging people into running a malicious computer program.

Warning Identity theft The Autorité des marchés financiers (AMF) is warning professionals about the extensive fraudulent and malicious use of its name engaging people into running a malicious computer program.

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Operational Resilience / Outsourcing

BankWealth ManagerFintech

Banking & Credit Capital Markets & Trading Crypto & Digital Assets

🇺🇸 CFTC News high

September 17th 2025

CFTC Obtains $1.2M for Fraud Victims, $2.8M Overall From Florida Commodity Firm, Owner

No description available.

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Authorisation & Licensing

Broker DealerCrypto ExchangeAll Firms

🇫🇷 AMF Enforcement high

September 16th 2025

The AMF Enforcement Committee fines an asset management company for breaches of its professional obligations

Sanctions & settlements professional obligations Journalists Investment management companies The AMF Enforcement Committee fines an asset management company for breaches of its professional obligations

AI Analysis

The AMF Enforcement Committee fined an asset management company €400,000 on 9 September 2025 for multiple breaches of professional obligations, including deficient marketing disclosures, inadequate conflict of interest systems, non-operational valuation procedures, failure to oversee external experts, and deficient AML/CFT systems in managing AIFs and club deals. This enforcement action underscores the AMF's focus on operational robustness and investor protection in asset management, serving as a critical reminder for firms to ensure procedures are not only documented but fully operational and effective. Compliance teams should review this to benchmark internal controls, as it highlights personal accountability for senior managers and recurring AMF priorities in recent sanctions.

What Changed

This is an enforcement decision, not a regulatory change introducing new rules; it enforces existing professional obligations under AMF jurisdiction for asset managers.
Providing comprehensive, accurate, and understandable information to investors on fee retrocessions to distributors in AIF marketing.
Implementing effective systems for preventing and managing conflicts of interest, particularly in joint investments like club deals classified as Other AIFs.
Maintaining operational procedures for valuing real estate assets, including formalizing independent valuer work.
Adhering to programs of activity for selecting, evaluating, overseeing, and periodically assessing external experts.

Suggested Considerations

Conduct immediate gap analysis of investment procedures, marketing materials, conflict of interest policies, valuation processes, external expert oversight, and AML/CFT systems to ensure they are operational, documented, and traceable.
Verify investor disclosures on fee retrocessions are comprehensive and understandable; update marketing materials for AIFs and club deals accordingly.
Formalize independent valuer roles and implement monitoring for external experts per activity programs.
Enhance AML/CFT due diligence on fund assets/liabilities, including risk mapping and procedure testing.
Senior managers: Document personal oversight of compliance; train on attribution of breaches.

Key Dates

Banking & Credit Investment Management Wealth & Private Banking

🇮🇪 CBI Warning high

August 27th 2025

BW Financial Services (Clone) - Central Bank of Ireland Issues Warning on Unauthorised Firm

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Authorisation & Licensing

BankWealth ManagerFintech

Banking & Credit Investment Management Wealth & Private Banking

🇨🇭 FINMA News medium

August 26th 2025

Aktualisierte Sanktionsmeldung: ISIL (Da'esh) / Al-Kaida

Sectors:

Topics:

AML / Financial Crime Prudential / Capital Requirements Reporting & Disclosure

BankWealth ManagerAll Firms

🇮🇪 CBI Warning high

August 25th 2025

Pionew Ireland (Clone) - Central Bank of Ireland Issues Warning on Unauthorised / Unregistered Firm

Sectors:

Topics:

Crypto Exchange

🇮🇪 CBI Warning high

August 25th 2025

Cryptocom (Clone) – Central Bank of Ireland Issues Warning on Unauthorised Firm

Sectors:

Authorisation & Licensing Consumer Protection / Conduct AML / Financial Crime

Topics:

Crypto ExchangeFintech

Investment Management Wealth & Private Banking Capital Markets & Trading

🇮🇪 CBI Warning high

August 21st 2025

Clermont Meridian Trading - Central Bank of Ireland Issues Warning on Unauthorised Firm

Sectors:

Topics:

Authorisation & Licensing Consumer Protection / Conduct AML / Financial Crime

Broker DealerWealth ManagerFintech

Banking & Credit Investment Management Wealth & Private Banking

🇮🇪 CBI Warning high

August 21st 2025

Northern Trust Fund Managers (Ireland) Ltd (Clone) - Central Bank of Ireland Issues Warning on Unauthorised Firm

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Authorisation & Licensing

BankWealth ManagerAsset Manager

Investment Management Payments & E-Money Crypto & Digital Assets

🇮🇪 CBI Warning high

August 21st 2025

GasTrade - Central Bank of Ireland Issues Warning on Unauthorised Firm

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Authorisation & Licensing

FintechPayment ProviderCrypto Exchange

Investment Management Wealth & Private Banking Crypto & Digital Assets

🇮🇪 CBI Warning high

August 21st 2025

Beta-Tech - Central Bank of Ireland Issues Warning on Unauthorised Firm

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Authorisation & Licensing

FintechCrypto Exchange

Banking & Credit Wealth & Private Banking

🇮🇪 CBI Warning high

August 21st 2025

KPMG Ireland (Clone) - Central Bank of Ireland Issues Warning on Unauthorised Firm

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Authorisation & Licensing

BankWealth Manager

Banking & Credit Investment Management Payments & E-Money

🇨🇭 FINMA Enforcement critical

August 19th 2025

Aktualisierte Sanktionsmeldung: Islamischen Republik Iran

Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung des Anhangs 7 der Verordnung vom 11. November 2015 über Massnahmen gegenüber der Islamischen Republik Iran (SR 946.231.143.6) publiziert.

AI Analysis

On August 18, 2025, the Swiss State Secretariat for Economic Affairs (WBF) published an updated sanctions notification regarding Iran, specifically modifying Annex 7 of the Ordinance on Measures against the Islamic Republic of Iran (SR 946.231.143.6). This update is critical for Swiss financial institutions and businesses because it reflects the evolving sanctions landscape following the automatic reinstatement of UN Security Council resolutions on Iran's nuclear program in September 2025.

What Changed

The August 2025 notification updated the list of designated persons, entities, and organizations subject to Swiss sanctions against Iran. While the search results do not provide the specific details of individual entries added or removed from Annex 7, this type of notification typically reflects changes to the UN Security Council's consolidated sanctions list that Switzerland is obligated to implement under its Embargo Act (EmbG). The broader context shows that Switzerland was preparing for significant sanctions escalation: on December 12, 2025, the Swiss Federal Council conducted a total...

Suggested Considerations

*Immediate compliance obligations:
*Sanctions List Screening: Update all sanctions screening systems and databases to reflect the August 2025 Annex 7 modifications and subsequent December 2025 total revision
*Transaction Review: Conduct comprehensive review of existing Iranian counterparties, customers, and beneficiaries against updated FINMA-published lists
*Account Monitoring: Identify and freeze accounts or assets belonging to designated persons and entities; report frozen assets to authorities
*Reporting: File mandatory notifications with FINMA and relevant authorities regarding any identified matches or transactions with sanctioned parties

Key Dates

August 18, 2025

- WBF published updated sanctions notification for Iran (Annex 7 modifications)

August 28, 2025

- Germany, France, and UK triggered UN snapback mechanism

September 15, 2025

- Harmonization of sanctions ordinances entered into force (affecting financial sanctions procedures across multiple jurisdictions including Iran)

September 27, 2025

- UN nuclear-related sanctions against Iran automatically reinstated

September 28, 2025

- EU reactivated suspended sanctions related to Iran's proliferation activities

Compliance Impact

Urgency: CRITICAL

References

AI-generated analysis. May contain errors or omissions — verify with the original FINMA source before acting. Full disclaimer.

Sectors:

Topics:

AML / Financial Crime Reporting & Disclosure Operational Resilience / Outsourcing

BankAsset ManagerPayment Provider

Banking & Credit Wealth & Private Banking Payments & E-Money

🇨🇭 FINMA Enforcement high

August 19th 2025

Aktualisierte Sanktionsmeldung: Lybien

Das Staatssekretariat für Wirtschaft (SECO) hat eine Änderung der Liste der sanktionierten natürlichen Personen, Unternehmen und Organisationen der Verordnung vom 30. März 2011 über Massnahmen gegenüber Libyen (SR 946.231.149.82) publiziert.

AI Analysis

This FINMA publication announces an update by Switzerland's State Secretariat for Economic Affairs (SECO) to the sanctions list under the Ordinance of 30 March 2011 on Measures against Libya (SR 946.231.149.82), aligning Swiss sanctions with changes in the UN Libya sanctions regime. It matters for Swiss financial institutions as it triggers immediate screening and compliance obligations to avoid violations of asset freeze and related restrictions on designated persons, entities, or organizations. Failure to act promptly risks enforcement by FINMA.

What Changed

The core change is an amendment to the list of sanctioned natural persons, companies, and organizations in SR 946.231.149.82, as published by SECO. This reflects broader UN Security Council updates via Resolution 2769 (2025), which introduced new designation criteria for individuals/entities supporting armed groups or criminal networks through illicit exploitation/export of crude oil or refined petroleum from Libya, alongside exemptions for certain arms embargo activities, allowances for Libyan Investment Authority (LIA) frozen cash investments in low-risk deposits, and extensions of related...

Suggested Considerations

Screen immediately: Run full client, transaction, and asset portfolios against the updated SECO list (SR 946.231.149.82) for matches on newly added/removed designations.
Freeze assets: Identify and freeze any funds/economic resources of designated parties without delay; report to SECO/FINMA.
Cease dealings: Halt direct/indirect provision of funds, financial services, or trade facilitation to/from listed parties.
Update systems: Refresh sanctions screening tools, policies, and training; document compliance evidence.
Monitor related flows: Heighten scrutiny on Libyan petroleum trade, LIA assets, and arms-related exemptions per UN Resolution 2769.

Key Dates

Immediate upon publication (19 August 2025) DEADLINE

- Swiss firms must implement updated sanctions list screening and freeze applicable assets/transactions per FINMA/SECO requirements (https://www.finma.ch/en/news/2025/08/20250819-sr-946-231-149-82/)

1 May 2026

- Expiration of UN authorizations/measures on illicit petroleum exports from Libya (Resolution 2769)

15 May 2026

- End of UN Panel of Experts mandate monitoring Libya sanctions

Compliance Impact

Urgency: High - Immediate action required due to asset freeze obligations; non-compliance risks FINMA fines, reputational damage, or criminal liability under Swiss AML/sanctions laws. This matters amid evolving geopolitical risks (e.g., petroleum smuggling destabilizing Libya), as flagged in FINMA's 2025 Risk Monitor on sanctions evasion via financial flows (https://www.swlegal.com/en/insights/newsletter-detail/finma-risk-monitor-2025-finma-flags-nine-principal/). Firms with Libyan exposure face elevated audit scrutiny.

References

AI-generated analysis. May contain errors or omissions — verify with the original FINMA source before acting. Full disclaimer.

Sectors:

Topics:

BankWealth ManagerPayment Provider

Banking & Credit Investment Management Wealth & Private Banking

🇨🇭 FINMA Enforcement high

August 19th 2025

Aktualisierte Sanktionsmeldung: Südsudan

Das Staatssekretariat für Wirtschaft (SECO) hat eine Änderung des Anhangs 2 der Verordnung vom 12. August 2015 über Massnahmen gegenüber der Republik Südsudan (SR 946.231.169.9) publiziert.

AI Analysis

FINMA has published an update notifying financial intermediaries of changes to Annex 2 of the Ordinance on Measures against the Republic of South Sudan (SR 946.231.169.9), as announced by SECO on August 18, 2025, effective August 20, 2025. This matters because it imposes immediate asset freeze and transaction ban obligations on Swiss financial institutions with exposure to newly or modified sanctioned entities, aligning with UN Security Council Resolution 2206 (2015) and EU measures to address South Sudan's ethnic conflict, human rights violations, and humanitarian crisis. Compliance failure risks enforcement actions under the Embargo Act (EmbG) and AML regulations (GwG).

What Changed

- SECO amended Annex 2 of the Ordinance, likely adding, removing, or modifying listings of sanctioned persons, companies, or organizations related to South Sudan.
The update requires implementation of prohibitions (e.g., no new business), asset freezing for listed parties, and reporting of affected relationships to SECO.
Changes stem from ongoing enforcement of UN and EU sanctions, with Switzerland implementing via the Embargo Act; Annexes are dynamically updated.

Suggested Considerations

Screen client portfolios, transactions, and relationships against the updated SESAM database and Annex 2 via FINMA's website or MyFINMA portal.
Freeze assets of newly listed parties without delay; block prohibited transactions.
Report affected business relationships to SECO promptly; conduct additional GwG Art. 6 due diligence if suspicions arise, and file SARs with the Money Laundering Reporting Office (MROS) under Art. 9 GwG if unresolved.
Update internal sanctions screening systems and train staff; document compliance for audit trails.

Key Dates

18.08.2025

- SECO publishes amendment to Annex 2

19.08.2025

- FINMA issues public notification of the update

20.08.2025

- Amendment enters into force; asset freezes and prohibitions apply immediately

Compliance Impact

Urgency: High - Immediate effect from August 20, 2025, mandates asset freezes and reporting with no grace period, exposing non-compliant firms to FINMA enforcement, fines, or reputational damage under EmbG and GwG. South Sudan sanctions are niche but cumulative updates (e.g., similar to Sudan changes) heighten screening fatigue risks; firms with Africa desks must prioritize to avoid inadvertent violations amid dynamic listings.

References

AI-generated analysis. May contain errors or omissions — verify with the original FINMA source before acting. Full disclaimer.

Sectors:

Topics:

BankAll Firms

Banking & Credit Investment Management Wealth & Private Banking

🇨🇭 FINMA Enforcement high

August 19th 2025

Aktualisierte Sanktionsmeldung: Sudan

Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung (WBF) hat den Anhang 2 der Verordnung vom 25. Mai 2005 über Massnahmen gegenüber Sudan (SR 946.231.18) geändert.

AI Analysis

The Swiss Federal Department of Economic Affairs, Education and Research (WBF) has amended Annex 2 of the Ordinance of May 25, 2005, on Measures against Sudan (SR 946.231.18), updating Switzerland's sanctions list in alignment with the SESAM database managed by SECO. This change, effective immediately on a urgent basis, requires Swiss financial intermediaries to implement updated asset freezes and transaction restrictions without delay, heightening compliance risks amid ongoing international sanctions escalation on Sudan-related actors. It matters because non-compliance exposes firms to FINMA enforcement, reputational damage, and penalties under anti-money laundering and sanctions regimes.

What Changed

- Amendment to Annex 2 of SR 946.231.18, which lists designated persons, entities, and assets subject to sanctions such as asset freezes and prohibitions on making funds or economic resources...
Updates reflected in the official Swiss sanctions database SESAM (SECO Sanctions Management), published on the SECO website, ensuring harmonized implementation across Switzerland.
Urgent (dringliche) amendment entering into force immediately, bypassing standard consultation periods to address time-sensitive developments in the Sudan conflict. Specific details of added/removed...

Suggested Considerations

Screen against updated SESAM database: Immediately query SECO's Sanctions Management system and Annex 2 for new/updated designations; freeze any matching assets and report to SECO/FINMA as required.
Transaction screening and blocking: Halt any funds transfers, services, or economic resources to/from designated parties; document due diligence.
Internal compliance update: Review client portfolios, KYC files, and transaction monitoring systems for Sudan exposure; train staff and update policies.
Reporting obligations: Notify FINMA/SECO of any frozen assets or potential breaches within regulatory timelines (typically 30 days for suspicious activity under AMLA).
Audit and evidence retention: Maintain records of screening/compliance actions for FINMA inspections.

Compliance Impact

Urgency: High – The urgent effective date mandates immediate action to avoid violations, with FINMA's enforcement history showing fines up to CHF 500,000+ for sanctions breaches. This matters amid Sudan's escalating conflict, where global sanctions (e.g., EU/UK additions in 2025) increase circumvention risks via Swiss hubs, amplifying AML/Financial Crime exposure and FINMA scrutiny in its 2025 Risk Monitor on geopolitical flows.

References

AI-generated analysis. May contain errors or omissions — verify with the original FINMA source before acting. Full disclaimer.

Sectors:

Topics:

BankWealth ManagerAll Firms

Banking & Credit Payments & E-Money Crypto & Digital Assets

🇱🇺 CSSF Enforcement high

August 18th 2025

Circular CSSF 25/896

Adoption of the EBA Guidelines on internal policies, procedures and controls to ensure the implementation of Union and national restrictive measures (sanctions)

AI Analysis

Circular CSSF 25/896 adopts the EBA Guidelines EBA/GL/2024/14 and EBA/GL/2024/15, mandating Luxembourg financial institutions to establish robust internal policies, procedures, and controls for complying with EU and national restrictive measures (sanctions). This matters because it sets binding EU-wide standards to prevent sanctions violations and circumvention, with absolute obligations for immediate asset freezing and reporting, amid escalating geopolitical tensions.

What Changed

- Institutions must develop, implement, and maintain up-to-date policies, procedures, and controls for identifying, investigating, and applying restrictive measures without delay, including risk...
Management body responsibilities expanded: approve sanctions compliance strategy, oversee implementation, conduct at least annual assessments of exposure and controls, ensure remedial actions, and...
Screening and monitoring requirements: Maintain updated sanctions lists with immediate integration of changes; screen customer base, transactions, and datasets accurately; enable immediate...
Training and testing: Deliver regular, documented role-specific training; perform ongoing system testing for screening calibration, list accuracy, transaction monitoring effectiveness, and reporting.
Proportionality applies based on institution's size, activities, and exposure; PSPs and CASPs explicitly addressed with tailored controls.

Suggested Considerations

Conduct annual exposure assessments to sanctions risks and circumvention; update policies accordingly.
Appoint senior management/board-level responsibility for approving and overseeing sanctions strategy, including annual reviews and deficiency reporting.
Implement reliable screening systems for customers, transactions, and lists; define screenable datasets; test systems regularly for effectiveness (e.g., immediate freezing, accurate hits).
Provide documented training to relevant staff on sanctions, institutional exposure, and internal processes.
Establish processes for immediate action on matches: suspend transfers, freeze assets, report to Ministry of Finance/CSSF/FIU without delay; maintain whitelists only under strict conditions.

Compliance Impact

Urgency: High – With less than 12 months until the 30 December 2025 deadline (as of January 2026), firms face binding requirements for absolute compliance, including personal accountability for management bodies; non-compliance risks enforcement by CSSF, reputational damage, and fines amid frequent EU sanctions updates (e.g., Regulations 2025/1469, 2025/1476). This elevates sanctions from operational task to strategic board priority.

References

AI-generated analysis. May contain errors or omissions — verify with the original CSSF source before acting. Full disclaimer.

Sectors:

Topics:

AML / Financial Crime Senior Managers / Governance Reporting & Disclosure

BankPayment ProviderCrypto Exchange

Banking & Credit Investment Management Wealth & Private Banking

🇨🇭 FINMA News medium

August 13th 2025

Sanktionen: Harmonisierung von Sanktionsverordnungen

No description available.

Sectors:

Topics:

AML / Financial Crime Prudential / Capital Requirements Reporting & Disclosure

BankWealth ManagerAsset Manager

Banking & Credit Payments & E-Money Investment Management

🇨🇭 FINMA Enforcement critical

August 13th 2025

Aktualisierte Sanktionsmeldung: Republik Irak

Das Staatssekretariat für Wirtschaft (SECO) hat eine Änderung des Anhangs der Verordnung vom 7. August 1990 über Wirtschaftsmassnahmen gegenüber der Republik Irak (SR 946.206) publiziert.

AI Analysis

The Swiss State Secretariat for Economic Affairs (SECO) published an updated sanctions notification on August 13, 2025, reflecting modifications to the UN sanctions list targeting Iraq under the Ordinance of August 7, 1990 (SR 946.206). This update is automatically applicable in Switzerland and requires immediate compliance by all financial institutions and regulated entities, as Switzerland implements UN Security Council sanctions lists without delay through its automatic application framework.

What Changed

The UN Sanctions Committee modified the list of sanctioned individuals, companies, and organizations subject to Iraq-related sanctions on August 5, 2025. The specific modifications to the sanctions list were incorporated into Switzerland's SESAM database (SECO Sanctions Management), which serves as the authoritative sanctions reference for Swiss compliance purposes. Under Switzerland's automatic application ordinance adopted by the Federal Council on March 4, 2016, amendments to UN Security Council sanctions lists enter into force in Switzerland without delay.

Suggested Considerations

*Update screening systems immediately - Integrate the August 5, 2025 modifications into transaction monitoring and customer due diligence systems
*Review existing customer relationships - Screen all current customers, counterparties, and beneficial owners against the updated SESAM database
*Audit transaction history - Identify any transactions processed between August 5-13, 2025 that may have involved newly sanctioned parties
*Document compliance procedures - Maintain records demonstrating implementation of updated sanctions screening
*Train compliance staff - Ensure all relevant personnel understand the updated sanctions list and screening requirements

Key Dates

August 5, 2025

- UN Sanctions Committee decision modifying the Iraq sanctions list

August 13, 2025

- SECO published the updated sanctions notification and SESAM database modifications

Immediate

- Effective date in Switzerland (automatic application upon UN modification)

Compliance Impact

Urgency: CRITICAL

References

AI-generated analysis. May contain errors or omissions — verify with the original FINMA source before acting. Full disclaimer.

Sectors:

Topics:

AML / Financial Crime Reporting & Disclosure Operational Resilience / Outsourcing

BankPayment ProviderAll Firms

Banking & Credit Investment Management Payments & E-Money

🇨🇭 FINMA Enforcement high

August 13th 2025

Aktualisierte Sanktionsmeldung: Belarus

Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung der Anhänge 5, 13, 14 und 15 der Verordnung über Massnahmen gegenüber Belarus (SR 946.231.116.9) publiziert.

AI Analysis

The Swiss Federal Department of Economic Affairs, Education and Research (WBF) published updates to Annexes 5, 13, 14, and 15 of the Ordinance on Measures against Belarus (SR 946.231.116.9), aligning Switzerland with additional EU sanctions imposed on July 18, 2025, in response to Belarus's involvement in Russia's war against Ukraine. This matters for Swiss financial institutions as it expands asset freezes, reporting obligations, and prohibitions, strengthening sanctions parity with Russia to prevent circumvention and enhance enforcement effectiveness.

What Changed

The updates amend Annexes 5, 13, 14, and 15 of SR 946.231.116.9, incorporating EU measures beyond the 18th Russia sanctions package, focusing on goods, financial, and energy sectors. Specific enhancements include expanded lists of sanctioned goods for military/technological strengthening (Annex 3 updated 29.10.2025), high-priority goods (Annex 11a), and industrial strengthening goods (Annex 19).

Suggested Considerations

Screen clients, assets, and transactions against updated Annexes 5, 13-15, and related lists (e.g., Annexes 3, 11a, 19) for freezes and prohibitions; block and report frozen assets/business relationships to SECO immediately.
Conduct GwG Art. 6 due diligence on suspicions; if unresolved, file AML reports under Art. 9 GwG (SECO reporting does not exempt this).
Cease prohibited activities: no loans, insurance, deposits >CHF 100k from Belarusians, specialized messaging for payments, or dealings with National Bank of Belarus.
Update internal screening tools, policies, and training; monitor SECO/FINMA websites for ongoing Anhänge updates.
For trade/energy firms: Halt exports/imports of listed goods (e.g., oil, potash, machinery) and verify third-country counterparties.

Key Dates

15 September 2025

- Harmonization of financial sanctions across multiple regimes (including Belarus) enters into force, clarifying fund crediting on blocked accounts and reporting

30 October 2025

- New provisions from Bundesrat decision on 29 October 2025 enter into force, requiring immediate implementation of updated Belarus measures

12 December 2025

- Publication of list expansions by WBF/SECO

13 December 2025

- Expansions to sanctions lists for Russia/Belarus (including 22 persons, 42 entities, 116 ships, 45 trade firms, 5 banks) take effect

Compliance Impact

Urgency: High - Immediate effect from 30 October 2025 demands swift asset screening and reporting to avoid GwG/EmbG violations, with heightened FINMA scrutiny amid Russia-Belarus alignment and recent list expansions (e.g., December 2025). Non-compliance risks enforcement, reputational damage, and sanctions evasion facilitation penalties, especially as circumvention via third countries rises.

References

AI-generated analysis. May contain errors or omissions — verify with the original FINMA source before acting. Full disclaimer.

Sectors:

Topics:

BankWealth ManagerPayment Provider

Banking & Credit Investment Management Wealth & Private Banking

🇨🇭 FINMA Enforcement high

August 13th 2025

Aktualisierte Sanktionsmeldung: Moldau

Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung des Anhangs der Verordnung vom 28. Juni 2023 über Massnahmen betreffend Moldau (SR 946.231.156.5) publiziert.

AI Analysis

The Swiss Federal Department of Economic Affairs, Education and Research (WBF) published an update to Annex of the Ordinance on Measures concerning Moldova (SR 946.231.156.5) on August 11, 2025, expanding the sanctions list for Moldova-related destabilizing activities. This matters for Swiss financial intermediaries as it imposes immediate asset freeze and reporting obligations under the Embargo Act (EmbG) and Anti-Money Laundering Act (GwG), aligning Switzerland with EU measures to counter threats to Moldova's sovereignty amid regional instability.

What Changed

- Updated Sanctions List: The WBF amended the Annex to include additional natural or legal persons, organizations, or entities subject to financial sanctions, effective immediately upon publication.
Financial Sanctions Reinforced: Mandatory asset freezes (sperre von Vermögenswerten), prohibitions on making funds or economic resources available (Bereitstellungsverbote), and reporting requirements...
No Change to Core Ordinance: The underlying Ordinance from June 28, 2023, is unchanged, but the Annex expansion triggers re-screening of existing relationships.

Suggested Considerations

Screen Client Base: Immediately rescreen all existing and prospective clients, relationships, and transactions against the updated SECO/FINMA Moldova sanctions list via MyFINMA portal.
Freeze and Report Assets: Block all funds/economic resources of newly listed parties without delay; report details (e.g., account info, asset values) to SECO promptly.
AML Due Diligence: Conduct enhanced checks under Art. 6 GwG; if suspicions persist post-SECO report, file suspicious activity report (SAR) with MROS under Art. 9 GwG.
Internal Controls: Update screening tools, train staff, and document compliance to mitigate enforcement risk from FINMA.
Monitor Ongoing: Subscribe to FINMA MyFINMA alerts and SECO updates for further Annex changes.

Key Dates

28.06.2023

Original Ordinance effective date; (context for baseline measures)

11.08.2025

Publication of Annex update by WBF

12.08.2025

Measures enter into force; (based on similar recent updates; immediate effect standard)

Immediate (unverzüglich)

Report frozen assets to SECO

Compliance Impact

Urgency: High – Immediate asset blocking and SECO reporting are mandatory with no grace period, risking FINMA enforcement (e.g., fines, reputational damage) for non-compliance; matters due to expanding geopolitical risks in Eastern Europe, potential for rapid list growth, and overlap with high-volume Russia/Ukraine sanctions regimes.

References

AI-generated analysis. May contain errors or omissions — verify with the original FINMA source before acting. Full disclaimer.

Sectors:

Topics:

BankAsset ManagerAll Firms

Banking & Credit Wealth & Private Banking Payments & E-Money

🇨🇭 FINMA Enforcement high

August 13th 2025

Aktualisierte Sanktionsmeldung: Russland

Das Departement für Wirtschaft, Bildung und Forschung (WBF) hat die Erweiterung der Sanktionslisten betreffend Russland publiziert. Die Schweiz hat damit diverse Änderungen übernommen, welche die EU im Rahmen ihres 18. Sanktionspakets beschlossen hatte.

AI Analysis

This FINMA publication announces Switzerland's adoption of the EU's 18th sanctions package against Russia, expanding the sanctions lists with new designations and restrictions via the Swiss State Secretariat for Economic Affairs (SECO/WBF). It matters because Swiss financial institutions must immediately screen and freeze assets of newly listed parties, aligning with heightened FINMA enforcement on Russia sanctions risks amid ongoing geopolitical tensions. Compliance teams face elevated legal, reputational, and secondary sanctions exposure from US/EU measures.

What Changed

The core update involves Switzerland incorporating EU Council decisions from the 18th sanctions package, which typically include:
Additions to asset freeze lists targeting Russian individuals, entities, and sectors like energy, finance, and dual-use goods.
Expanded prohibitions on making funds or economic resources available to designated parties.
Alignment with EU sectoral restrictions on Russia's financial messaging services (e.g., SPFS), oil trade, and shadow fleet activities, now binding in Switzerland via ordinances updated by WBF/SECO.

Suggested Considerations

Enhance customer due diligence (CDD): Review existing Russia/Ukraine portfolios for matches; implement enhanced monitoring for shadow fleet, oil traders, and FIMI-linked entities.
Report to FINMA/SECO: Notify of any frozen assets or potential breaches; document compliance efforts to mitigate enforcement risks.
Update policies: Integrate EU 18th package into internal sanctions frameworks, including red flags for circumvention (e.g., crypto, third-country banks).
Train staff: Conduct urgent refreshers on secondary sanctions risks per FINMA Risk Monitor 2025.

Key Dates

Immediate upon publication (August 13, 2025)

- Swiss sanctions lists updated; asset freezes and prohibitions take effect instantly for newly designated parties

15 December 2025

- Noted FINMA reference for ongoing list updates and independent freezing measures

31 July 2026

- EU sectoral sanctions against Russia renewed until this date (adopted December 2025), influencing Swiss alignment

Compliance Impact

Urgency: High - This directly expands enforceable prohibitions, with FINMA's targeted on-site reviews and "very high" Russia sanctions risk rating amplifying enforcement (https://www.finma.ch/en/~/media/finma/dokumente/dokumentencenter/myfinma/finma-publikationen/risikomonitor/20251117-finma-risikomonitor-2025.pdf?sc_lang=en). Non-compliance risks fines, reputational damage, and secondary US sanctions, especially post-EU renewals through 2026.

References

AI-generated analysis. May contain errors or omissions — verify with the original FINMA source before acting. Full disclaimer.

Sectors:

Topics:

BankWealth ManagerAll Firms

🇮🇪 CBI Warning high

August 5th 2025

Pass Investment Managers (Clone) - Central Bank of Ireland Issues Warning on Unregistered Firm

Sectors:

AML / Financial Crime Authorisation & Licensing Consumer Protection / Conduct

Topics:

Crypto ExchangeFintech

Consumer Credit Banking & Credit

🇮🇪 CBI Warning high

August 5th 2025

Lending Loans - Central Bank of Ireland Issues Warning on Unauthorised Firm

Sectors:

Topics:

Consumer Protection / Conduct Authorisation & Licensing AML / Financial Crime

BankFintech

Banking & Credit Wealth & Private Banking Investment Management

🇨🇭 FINMA Enforcement critical

July 31st 2025

Verordnung vom 7. März 2025 über die Sperrung von Vermögenswerten im Zusammenhang mit Syrien (Anpassung des Anhangs)

No description available.

AI Analysis

On July 31, 2025, Switzerland's State Secretariat for Economic Affairs (SECO) amended the annex to the Syria Asset Freezing Ordinance (SR 196.127.27), originally enacted March 7, 2025, to update the list of designated individuals subject to comprehensive asset freezes. This amendment reflects Switzerland's ongoing implementation of targeted financial sanctions against politically exposed persons connected to the former Assad regime, requiring immediate compliance from all financial intermediaries and asset holders operating in Swiss jurisdiction.

What Changed

The July 31, 2025 amendment modified the annex (list of designated persons) to the Syria Asset Freezing Ordinance without altering the substantive freezing requirements themselves. The original ordinance, enacted March 7, 2025, froze all assets of 17 designated individuals; the July amendment adjusted this list, though the specific names added or removed are not detailed in the available regulatory notices. The amendment operates under the Federal Act on the Freezing and Restitution of Illicit Assets held by Foreign Politically Exposed Persons (FIAA; SR 196.1), which provides the legal...

Suggested Considerations

*Immediate compliance steps for financial institutions:
*Update sanctions screening systems to reflect the amended annex list as of July 31, 2025
*Freeze all assets of newly designated individuals without delay, including bank accounts, securities, real estate, and other property of any kind
*File mandatory reports with the Money Laundering Reporting Office (MROS) for all frozen assets under Article 3 of the FIAA
*Conduct enhanced due diligence on existing client relationships to identify any connections to designated persons or their family members, associates, or controlled entities

Key Dates

March 7, 2025, 6:00 PM UTC

– Original Syria Asset Freezing Ordinance entered into force

July 31, 2025, 6:00 PM UTC

– Amendment to annex (list of designated persons) entered into force

Ongoing

– Immediate freezing obligation upon designation; no grace period applies

Four

year validity; – The ordinance remains valid for four years from March 7, 2025, unless extended or modified

Compliance Impact

Urgency: CRITICAL

References

AI-generated analysis. May contain errors or omissions — verify with the original FINMA source before acting. Full disclaimer.

Sectors:

Topics:

BankWealth ManagerAsset Manager

Banking & Credit Investment Management Capital Markets & Trading

🇫🇷 AMF News high

July 17th 2025

The AMF and the AFA call for vigilance of the risk of private corruption by criminal networks of natural persons with access to inside information

MAR Financial disclosures & corporate financing Shares The AMF and the AFA call for vigilance of the risk of private corruption by criminal networks of natural persons with access to inside information

Sectors:

Topics:

AML / Financial Crime Market Abuse / Surveillance Reporting & Disclosure

BankAsset ManagerBroker Dealer

Banking & Credit Investment Management Payments & E-Money

🇨🇭 FINMA Enforcement high

July 9th 2025

Aktualisierte Sanktionsmeldung: Haiti

AI Analysis

The Swiss Federal Department of Economic Affairs, Education and Research (WBF) has published an update to Annex 2 of the Ordinance on Measures concerning Haiti (SR 946.231.139.4), dated December 16, 2022, aligning Switzerland's sanctions regime with recent UN Security Council decisions. This matters for Swiss financial institutions as it mandates immediate screening against potentially updated lists of designated persons and entities, reinforcing asset freezes, travel bans, and an expanded arms embargo to address Haiti's instability. Non-compliance risks FINMA enforcement actions under anti-money laundering and sanctions frameworks.

What Changed

- Annex Update: The amendment modifies the annex to the Haiti Ordinance, likely incorporating additions to the UN Sanctions List, such as new designated individuals or entities involved in...
Sanctions Renewal and Expansion: Reflects UNSC Resolution 2752 (2024, adopted October 18, 2024) and subsequent renewals (e.g., Resolution 2794 (2025)), renewing travel bans, asset freezes, and arms...
Swiss Implementation: FINMA oversees enforcement via SECO's sanction ordinances; updates require alignment with UN lists for asset freezing and prohibitions on dealings with designated parties.

Suggested Considerations

Screen Immediately: Check client databases, accounts, and transactions against the updated SECO/UN Haiti Sanctions List for new designations; freeze assets/economic resources without prior notice.
Cease Prohibited Activities: Halt dealings (direct/indirect) with designated parties, including financial services, brokering, technical assistance, or transfers related to military goods/technology.
Report Findings: Notify SECO/FINMA of matches or frozen assets, providing additional compliance details; maintain records for audits.
Update Policies/Systems: Revise sanctions screening tools, train staff, and monitor for "connected persons" under updated definitions.
License Checks: Apply for exemptions only if explicitly available (e.g., humanitarian); no dealings without approval.

Key Dates

October 17/20, 2025

UNSC Committee adds 2 entries to Sanctions List; Triggers immediate asset freeze checks; Swiss update (SR 946.231.139.4) published in response

October 18, 2024

UNSC Resolution 2752 adoption; Expands arms embargo scope, basis for national implementations

Immediate/publication date (2025/07/09 per FINMA notice)

Swiss Annex amendment effective; No grace period specified; aligns with "without delay" freezing requirements

July 23, 2025

UK Haiti Sanctions Amendment effective; Parallel indicator of timeline for UN-aligned changes

October 21, 2025

Swiss WBF/VTG announcement; Confirms amended sanctioned list

Compliance Impact

Urgency: High – Immediate asset freeze obligations apply "without delay" upon list updates, with FINMA's enforcement type indicating potential fines or reputational damage for lapses; matters due to Haiti's volatility driving frequent UN changes, risking secondary sanctions exposure for Swiss firms with international ties.

References

AI-generated analysis. May contain errors or omissions — verify with the original FINMA source before acting. Full disclaimer.

Sectors:

Topics:

BankPayment ProviderAll Firms

Banking & Credit Wealth & Private Banking Payments & E-Money

🇨🇭 FINMA Enforcement high

June 26th 2025

Aktualisierte Sanktionsmeldung: Guatemala

Das Eidgenössische Departement für Wirtschaft, Bildung und Forschung WBF hat eine Änderung des Anhangs der Verordnung über Massnahmen betreffend Guatemala (SR 946.231.137.6) publiziert.

AI Analysis

The Swiss Federal Department of Economic Affairs, Education and Research (WBF) has published an update to Annex 2 of the Ordinance on Measures concerning Guatemala (SR 946.231.137.6), aligning Swiss sanctions with international developments targeting threats to democracy and rule of law in Guatemala. This matters for Swiss financial institutions as it mandates immediate screening and blocking of newly designated persons/entities to prevent sanctions violations, reinforcing Switzerland's commitment to international sanctions regimes amid ongoing geopolitical tensions in Central America. https://www.finma.ch/en/news/2025/06/20250626-sr-946-231-137-6/

What Changed

- Amendment to Annex 2 of SR 946.231.137.6, likely adding or updating designations of individuals, groups, or entities involved in undermining Guatemala's democracy, rule of law, or election...
Measures include asset freezes (prohibiting Swiss persons from dealing with designated assets) and transaction prohibitions, with independent freezing by FINMA where required under Swiss law.
Updates are published in the Federal Gazette and integrated into FINMA's continuously maintained sanctions lists for automated screening.

Suggested Considerations

Immediate screening: Run updated Annex 2 against client databases, transactions, and assets; block and report any matches to FINMA via SR system.
Enhanced due diligence: Review Guatemala exposures for links to designated parties (e.g., Public Prosecutor’s Office officials, FCT); suspend dealings and notify self-certification.
System updates: Ensure sanctions screening tools (e.g., World-Check, Refinitiv) reflect changes; train staff and document compliance.
Reporting: File suspicious activity reports (SARs) to MROS if pre-existing dealings detected; retain evidence of non-execution of prohibited transactions. https://www.finma.ch/en/news/2025/06/20250626-sr-946-231-137-6/

Key Dates

26 June 2025

- Publication of annex amendment by WBF; immediate effectiveness for screening and blocking obligations

15 December 2025

- Reference date for related FINMA sanctions annex maintenance (not specific to this update but indicative of cycle). https://www.finma.ch/en/news/2025/06/20250626-sr-946-231-137-6/ https://www.finma.ch/en/documentation/international-sanctions-and-combating-terrorism/international-sanctions-and-independent-freezing-measures/

Ongoing (continuous) DEADLINE

- Annex updates published in Federal Gazette; firms must integrate changes without specified delay

Compliance Impact

Urgency: High - Swiss sanctions take effect immediately upon publication, exposing non-compliant firms to FINMA enforcement (fines up to CHF 1M, reputational damage). This aligns with rising geopolitical risks flagged in FINMA Risk Monitor 2025, where sanctions evasion amid corruption flows could trigger audits; failure risks secondary sanctions under EU/US regimes. https://www.finma.ch/en/news/2025/06/20250626-sr-946-231-137-6/ https://www.swlegal.com/en/insights/newsletter-detail/finma-risk-monitor-2025-finma-flags-nine-principal/

References

AI-generated analysis. May contain errors or omissions — verify with the original FINMA source before acting. Full disclaimer.

Sectors:

Topics:

BankWealth ManagerPayment Provider

Investment Management Capital Markets & Trading

🇨🇭 FINMA News medium

June 19th 2025

Anti-money Laundering Asset management AMF invites financial market participants to take part in the EBA consultation on draft AML/CFT implementing standards

AI Analysis

The AMF is urging French financial market participants to engage in the EBA's consultation launched on March 6, 2025, on draft Regulatory Technical Standards (RTS) for AML/CFT implementing standards under AMLD6 and AMLR, focusing on harmonized risk assessment methodologies for supervisors and obliged entities. This matters because it signals a shift to uniform EU-wide AML/CFT supervision via AMLA (post-EBA handover on January 1, 2026), requiring firms to adapt to standardized risk indicators, data reporting, and enforcement, with new CDD rules applying from July 2027. Participation ensures firms influence final standards amid the transition to a single EU AML rulebook.

What Changed

The draft RTS propose harmonized methodologies for AML/CFT supervision, including:
Risk Assessment of Obliged Entities (Article 40(2) AMLD6): A three-step process with indicators for inherent risk (customers, products/services, geography, distribution channels), control...
Risk Assessment for Direct Supervision (Article 12(7) AMLAR): Two-stage selection for AMLA direct oversight of high-risk cross-border firms (operating in ≥6 Member States, meeting...
CDD Updates: Risk-based approach for new customers from July 2027; five-year transition for existing customers, prioritizing high-risk.
Pecuniary Sanctions RTS (Article 53(10) AMLD6): Structured classification of breaches, proportionate sanctions, and enforcement for serious/repeated/systematic infringements to ensure uniformity...

Suggested Considerations

Participate in EBA consultation: Submit feedback on draft RTS via EBA channels, focusing on risk indicators, data frequency, and feasibility; AMF encourages French firms to act promptly.
Conduct compliance gap analysis: Review current AML frameworks against proposed indicators (inherent risk, controls, residual risk); prioritize high-risk customers/products.
Enhance systems: Invest in regtech for automated risk scoring, transaction monitoring, and data reporting to supervisors; update governance, policies, and CDD processes.
Prepare for AMLA supervision: For cross-border firms, model group-wide risk profiles; develop remediation plans for breaches.
Ongoing monitoring: Implement annual risk reviews and ad-hoc reassessments for business changes.

Key Dates

March 6, 2025

EBA consultation launch; on draft RTS for AML/CFT standards (ongoing as of analysis)

January 1, 2026

Sanctions & settlements professional obligations Journalists Investment management companies The AMF Enforcement Committee fines a financial investment advisor, two asset management companies and their directors, and a credit institution a total of €5,670,000

AI Analysis

The AMF Enforcement Committee imposed total fines of €5,670,000 on a financial investment advisor (FIA), two asset management companies (AMCs), their directors, and a credit institution for breaches of professional obligations. This enforcement action underscores the AMF's rigorous scrutiny of operational controls, due diligence, and governance in investment services, serving as a critical reminder for firms to maintain robust procedures to avoid similar sanctions. It matters because it highlights personal liability for directors and escalating fines for systemic failures, potentially influencing peer reviews and audit priorities.

What Changed

This is an enforcement decision, not a regulatory change introducing new rules. It reinforces existing AMF requirements under professional obligations, including:
Implementation of operational procedures for investment/divestment processes, such as verifying lender authorizations.
Systematic anti-money laundering (AML) and counter-terrorism financing (CTF) due diligence on fund assets and liabilities.
Justification of retrocessions (rebates) to distributors, proving enhanced client service quality.
Honest, fair, and diligent business conduct with requisite skill and care, extending to marketing materials and advisory services. No new requirements; emphasis on enforcement of MiFID II-aligned...

Suggested Considerations

Conduct gap analysis of operational procedures for investments/divestments, ensuring lender authorization checks (reference AMF Position-Recommendation DOC-2020-05 on portfolio management).
Review AML/CTF due diligence frameworks for fund assets/liabilities, aligning with AMF Regulation 2016-01.
Audit retrocession practices to distributors, documenting service quality enhancements (per AMF doctrine on inducements).
Update marketing materials and advisory processes for compliance with honesty/fairness standards.
Enhance senior manager attestations and training on personal liability under CMF L.621-15-1.

🇫🇷 AMF Enforcement high

September 19th 2024

The AMF Enforcement Committee fines Sogenial Immobilier and its chairman a total of €180,000

Sanctions & settlements professional obligations Journalists Investment management companies The AMF Enforcement Committee fines Sogenial Immobilier and its chairman a total of €180,000

AI Analysis

The AMF Enforcement Committee issued a €180,000 combined fine against Sogenial Immobilier (€150,000) and its chairman Jean-Marie Souclier (€30,000) on September 12, 2024, for systematic breaches of professional obligations spanning investment selection, regulatory disclosure, conflict of interest management, and anti-money laundering compliance. This enforcement action demonstrates the AMF's heightened scrutiny of asset managers' operational controls and substantive compliance with fund governance requirements, particularly regarding real estate investment companies (SCPIs).

What Changed

The decision does not introduce new regulatory requirements but rather clarifies enforcement expectations across existing obligations:
Regulatory Documentation Standards: Asset managers must implement documented procedures governing the preparation of all regulatory and marketing materials for alternative investment funds, with...
Investment Due Diligence Standards: A "high standard of diligence" is required when selecting investments, with formal investment procedures that must be consistently followed and documented.
Conflict of Interest Management: Specific controls must address conflicts in asset allocation decisions, with documented decision-making processes that demonstrate conflict mitigation.
AML/CFT Implementation: Anti-money laundering and combating the financing of terrorism procedures must be applied comprehensively to both fund-level investments and individual client subscriptions,...

Suggested Considerations

*Audit Existing Procedures: Review and document all procedures governing regulatory and marketing materials for alternative investment funds, ensuring they address risk disclosure accuracy and asset return reporting requirements.
*Formalize Investment Selection Process: Document and implement investment selection procedures that demonstrate application of "high standard of diligence," including documented investment committee decisions, due diligence checklists, and approval workflows.
*Enhance Conflict of Interest Controls: Map all potential conflicts in asset allocation decisions and implement specific controls (e.g., segregation of duties, documented approvals, independent review) for each identified conflict scenario.
*Implement Comprehensive AML/CFT: Extend AML/CFT procedures to cover both fund-level investments and individual client subscriptions, with documented customer due diligence, beneficial ownership verification, and transaction monitoring.
*Strengthen Internal Control Functions: Establish or enhance internal audit/compliance functions with documented monitoring controls covering investments, conflicts of interest, and AML/CFT, with regular reporting to management and governance bodies.

Key Dates

September 12, 2024

- AMF Enforcement Committee issued the decision

September 16, 2024

- Public announcement of sanctions

No specified deadline DEADLINE

- Appeal period remains open (appeals may be lodged against the decision)

Compliance Impact

Urgency: HIGH

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Reporting & Disclosure

Asset Manager

Banking & Credit Investment Management Wealth & Private Banking

🇮🇪 CBI News

September 13th 2024

Issue 7 2024

No description available.

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Prudential / Capital Requirements

Asset ManagerBankWealth Manager

Banking & Credit Investment Management Crypto & Digital Assets

🇫🇷 AMF Warning high

July 24th 2024

The AMF reminds retail investors to be extremely vigilant regarding Immediate Connect's fraudulent investment offer

Warning Savings protection Warning Forex and binary options Crypto-assets The AMF reminds retail investors to be extremely vigilant regarding Immediate Connect's fraudulent investment offer

Sectors:

Topics:

Consumer Protection / Conduct AML / Financial Crime Authorisation & Licensing

Crypto ExchangeFintechAll Firms

🇫🇷 AMF Enforcement high

July 17th 2024

AMF Enforcement Committee fines an asset management company and its directors for breaches of their professional obligations

Sanctions & settlements professional obligations Journalists Investment management companies AMF Enforcement Committee fines an asset management company and its directors for breaches of their professional obligations

AI Analysis

The AMF Enforcement Committee fined asset management company M Capital Partners €200,000 and its directors Rudy Secco (€70,000) and Stéphanie Minissier (€35,000) on 31 December 2025 for breaches of professional obligations spanning August 2019 to December 2023, including unauthorized investment services, deficient investment processes, conflicts of interest failures, and inadequate AML/CFT systems. This decision underscores AMF's focus on operational robustness and personal accountability in asset management, serving as a regulatory warning for firms to strengthen internal controls or face escalating sanctions.

What Changed

This is an enforcement action, not a new regulation, but it reinforces existing AMF requirements under French Monetary and Financial Code for asset managers:
Operational procedures: Investment allocation processes must be precise, traceable, and fully operational; failure to verify compliance (e.g., loan authorizations) breaches honesty, fairness, and...
Scope of services: Asset managers acting as tied agents cannot provide unauthorized services like placing financial instruments without firm commitment, circumventing permitted investment services.
Conflicts of interest: Systems must effectively identify, prevent, and manage conflicts.
AML/CFT due diligence: Procedures, risk mapping, and due diligence on fund assets/liabilities must be operational and systematic.

Suggested Considerations

Conduct gap analysis: Immediately review investment processes, allocation rules, and traceability against AMF standards; verify authorization of lending entities and service scopes.
Enhance AML/CFT: Update procedures, risk mappings, and due diligence on fund assets/liabilities; ensure operational effectiveness with documented evidence.
Strengthen governance: Implement robust conflicts of interest systems; formalize senior manager oversight with personal accountability training.
Audit marketing/distribution: For tied agents or retrocessions, document service quality enhancements to clients.
Senior manager certification: Directors must attest to compliance in annual reporting; prepare for AMF inspections by maintaining verifiable records.

Key Dates

August 2019

December 2023; - Period of identified breaches (investment services, processes, AML/CFT deficiencies)

31 December 2025

- AMF Enforcement Committee decision date imposing fines on M Capital Partners and directors

08 January 2026

- Public press release publication date

Compliance Impact

Urgency: High - This recent (Dec 2025) decision, alongside similar fines (e.g., €1.3M on Altaroc Partners in Sep 2025, €400k on Eternam in Sep 2025), signals AMF's intensified scrutiny on asset manager operations post-AIFMD reviews, with personal fines rising (up to €500k+). Non-compliance risks enforcement, reputational damage, and appeals delays; act within 3-6 months to align before potential audits.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

AML / Financial Crime Senior Managers / Governance Consumer Protection / Conduct

Topics:

Asset Manager

🇫🇷 AMF Consultation medium

July 11th 2024

The AMF publishes the summary of responses received to its Discussion Paper on Decentralised Finance

Crypto-assets Innovation The AMF publishes the summary of responses received to its Discussion Paper on Decentralised Finance

AI Analysis

The Autorité des Marchés Financiers (AMF) has published a summary of stakeholder responses to its June 2023 Discussion Paper on Decentralised Finance (DeFi), analyzing regulatory challenges posed by automated, decentralized crypto-asset activities. This matters for compliance professionals as it signals the AMF's ongoing commitment to developing a balanced DeFi framework amid MiCA's implementation, potentially shaping future supervision of decentralized protocols while emphasizing investor protection and innovation.

What Changed

No immediate regulatory changes or new requirements are introduced; this is a non-binding summary of consultation feedback from July 2024, intended to inform future discussions rather than enact rules. It highlights stakeholder views on DeFi's challenges, such as decentralization's impact on traditional oversight, with the AMF planning continued ecosystem engagement to outline proportionate responses.

Suggested Considerations

Monitor and engage: Participate in AMF's ongoing DeFi discussions and tokenization consultations for asset managers; no mandatory actions from this summary alone.
MiCA compliance: DASPs must apply for CASP licenses or leverage exemptions (e.g., notify AMF with operational/AML details if regulated entities); ensure AML/CTF alignment with EBA/TFR "Travel Rule" extensions.
Assess decentralization: DeFi protocols should evaluate if they qualify as "sufficiently decentralized" to evade DASP rules; traditional firms notify AMF before crypto services.
Update policies: Incorporate AMF clarifications on DASP transitions (DOC-2019-23/24 updates) and prepare for 2026 priorities like DORA cybersecurity.

Key Dates

June 2023

- AMF publishes initial Discussion Paper on DeFi regulatory challenges

July 2024

Sanctions & settlements Journalists The AMF Enforcement Committee fines an asset management company and its directors for breaches of their professional obligations

AI Analysis

The AMF Enforcement Committee fined asset management company M Capital Partners €200,000 and its directors Rudy Secco (€70,000) and Stéphanie Minissier (€35,000) on 31 December 2025 for breaches of professional obligations spanning August 2019 to December 2023, including unauthorized investment services, deficient investment processes, conflicts of interest failures, and inadequate AML/CFT systems. This decision underscores AMF's focus on operational robustness in asset managers, particularly those acting as tied agents, and holds senior managers personally accountable. It matters for compliance as it exemplifies enforcement trends targeting systemic deficiencies, with potential appeals signaling ongoing scrutiny.

What Changed

This is an enforcement action, not a regulatory change, but it reinforces existing AMF requirements under French Monetary and Financial Code for asset managers:
Operational procedures: Investment allocation processes must be precise, traceable, and compliant; failure to verify or document renders systems non-operational.
Scope of services: Asset managers (and tied agents) cannot provide unauthorized services like placing financial instruments without firm commitment, circumventing licensed activities.
Conflicts of interest: Robust identification, prevention, and management systems are mandatory.
AML/CFT: Due diligence on fund assets/liabilities must be systematic and operational, with effective risk mapping and procedures.

Suggested Considerations

Immediate gap analysis: Review investment procedures for precision, traceability, and operationality; verify authorization of lending entities and service scopes (e.g., no unauthorized placement services).
Enhance AML/CFT: Implement operational risk mapping, systematic due diligence on fund assets/liabilities, and evidence of effectiveness.
Conflicts framework: Formalize identification/prevention processes, especially in multi-role firms (asset manager + tied agent).
Senior manager attestation: Document personal oversight; conduct training on attribution of breaches.
Marketing/retrocessions: Ensure traceability and proof of client benefit (cross-reference with similar findings).

Key Dates

August 2019

December 2023; - Period of breaches investigated, covering investment services, processes, conflicts, and AML/CFT failures

31 December 2025

- AMF Enforcement Committee decision date imposing fines on M Capital Partners and directors

08 January 2026

- Public press release date

Compliance Impact

Urgency: High - This reflects a pattern of 2025 AMF fines on asset managers for operational/AML failures (e.g., €1.3M on Altaroc Partners 15 Sep 2025; €400k on Eternam 9 Sep 2025), signaling intensified scrutiny post-AIFMD reviews. Matters due to personal liability for managers, appeal risks amplifying precedent, and applicability to hybrid models; non-compliance risks fines scaling to €1M+ and reputational damage.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

AML / Financial Crime Senior Managers / Governance Authorisation & Licensing

Topics:

Asset Manager

🇫🇷 AMF Enforcement high

July 31st 2023

The AMF Enforcement Committee fines an asset management company for breaches of its professional obligations

AI Analysis

The AMF Enforcement Committee fined asset management company Altaroc Partners (formerly Amboise Partners SA) €600,000 and its senior managers Maurice Tchenio (€500,000) and Patrick de Giovanni (€200,000) on 15 September 2025 for multiple breaches of professional obligations, including lack of operational procedures for fund investments/divestments, inadequate AML/CFT due diligence, unproven benefits of fee retrocessions to distributors, and shortcomings in marketing materials. This decision underscores the AMF's strict enforcement on operational controls, governance, and client protection in asset management, serving as a critical warning for firms to ensure robust, documented procedures and senior manager accountability. It matters because it highlights personal liability for executives and reinforces AMF's educational role through sanction explanations, potentially increasing scrutiny on similar firms.

What Changed

This is an enforcement action, not a regulatory change; it reaffirms and clarifies existing obligations under French financial regulations for asset managers (sociétés de gestion de portefeuille).
Implementing operational procedures for investment/divestment processes, including verification of lender authorizations.
Conducting systematic AML/CFT due diligence on fund assets and liabilities.
Proving that fee retrocessions to distributors enhance client service quality.
Ensuring marketing materials are accurate and compliant. These align with ongoing AMF expectations for "honest, fair, professional" conduct with requisite skill, care, and diligence.

Suggested Considerations

Review and document operational procedures for fund investments/divestments, including lender authorization checks.
Enhance AML/CFT systems with systematic due diligence on fund assets/liabilities and risk mapping.
Audit fee retrocession arrangements to demonstrate tangible client service improvements (e.g., via evidence of enhanced distribution quality).
Validate marketing materials for accuracy and completeness.
Conduct senior manager attestations on compliance oversight; implement training on personal liability.

Key Dates

15 September 2025

- AMF Enforcement Committee decision issued, imposing fines on Altaroc Partners and managers

16 September 2025

- French version of press release published

Post

15 September 2025; - Appeal lodged by Altaroc Partners, Tchenio, and de Giovanni before the Conseil d’État against decision SAN-2025-09 (exact date not specified)

Compliance Impact

Urgency: High - This recent (2025) enforcement demonstrates AMF's willingness to impose multimillion-euro fines (€1.3M total) and hold executives personally accountable for systemic failures in core areas like operations, AML, and client disclosure. It matters for immediate risk as appeals are pending but do not suspend obligations; firms with similar setups face elevated audit risk, especially amid AMF's pattern of targeting asset managers (e.g., 5+ cases in 2024-2025).

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

AML / Financial Crime Consumer Protection / Conduct Senior Managers / Governance

Topics:

Asset Manager

Banking & Credit Investment Management Wealth & Private Banking

🇫🇷 AMF News medium

July 28th 2023

Anti-money laundering and combating the financing of terrorism: the AMF applies the guidelines of the European Banking Authority

Anti-money Laundering Asset management Anti-money laundering and combating the financing of terrorism: the AMF applies the guidelines of the European Banking Authority

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Prudential / Capital Requirements

Asset ManagerBankWealth Manager

Capital Markets & Trading Crypto & Digital Assets Investment Management

🇫🇷 AMF Enforcement high

July 5th 2023

Pump-and-dump practice: market manipulation sanctioned by the Paris Tribunal Correctionnel

MAR Anti-money Laundering Pump-and-dump practice: market manipulation sanctioned by the Paris Tribunal Correctionnel

AI Analysis

The Paris Tribunal Correctionnel sanctioned a pump-and-dump market manipulation scheme, where perpetrators artificially inflated small-cap stock prices via social media hype before selling off, violating France's Market Abuse Regulation (MAR). This enforcement action by the AMF underscores aggressive judicial backing for anti-manipulation efforts, signaling heightened scrutiny on coordinated trading schemes, especially in illiquid assets. Compliance teams must prioritize surveillance enhancements to mitigate similar risks amid rising digital promotion tactics.

What Changed

This is an enforcement decision rather than new legislation, reinforcing existing prohibitions under Regulation (EU) No 596/2014 (MAR) against market manipulation, including pump-and-dump tactics like false information dissemination and artificial price inflation . No novel regulatory requirements are introduced, but it exemplifies AMF's collaboration with courts for criminal sanctions, potentially increasing deterrence through public naming and fines. Related AMF General Regulation updates effective 30/06/2026 integrate MAR references and strengthen reporting of failings .

Suggested Considerations

Enhance market abuse surveillance systems to detect coordinated trading, unusual volume spikes, and social media-driven hype in small-cap/illiquid assets.
Implement staff training on recognizing pump-and-dump indicators, such as group chats luring investors with upside promises .
Review client communications policies to block manipulative promotions; report suspicions under MAR Article L.634-1 procedures .
For crypto firms, align with "enhanced" DASP registration and MiCA AML/CFT compliance to preempt manipulation sanctions .
Conduct internal audits of trading patterns and escalate to AMF if risks identified.

Key Dates

30 December 2024

- MiCA mandatory licensing for CASPs; pre-registered PSANs enter 18-month transition

30 June 2026 DEADLINE

- End of PSAN transitional period; full MiCA authorization required, with AMF oversight on manipulation risks

Compliance Impact

Urgency: High - This case demonstrates swift judicial enforcement (Tribunal Correctionnel conviction), amplifying personal liability for individuals in manipulation schemes and pressuring firms to bolster pre-trade/post-trade surveillance. It matters amid MiCA deadlines, as unlicensed crypto operators risk exclusion post-2026, with pump-and-dump flagged as a key abuse vector . Non-compliance invites AMF inspections, fines, and reputational damage in a litigious environment.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

Topics:

Broker DealerCrypto ExchangeAll Firms

Crypto & Digital Assets Capital Markets & Trading Payments & E-Money

🇫🇷 AMF Consultation medium

June 19th 2023

The AMF publishes a discussion paper on Decentralised Finance (DeFi)

Crypto-assets Innovation Fintech Journalists The AMF publishes a discussion paper on Decentralised Finance (DeFi)

AI Analysis

The Autorité des Marchés Financiers (AMF), France's financial markets regulator, published a discussion paper on June 19, 2023, outlining preliminary thoughts on regulatory challenges posed by Decentralised Finance (DeFi) activities on crypto-assets, inviting stakeholder feedback by September 30, 2023. A summary of responses was released on July 10, 2024, highlighting key themes like defining DeFi, distinguishing protocol types, and applying a "same activity, same risk, same regulation" principle. This matters for compliance professionals as it signals AMF's intent to develop proportionate DeFi oversight, balancing innovation with investor protection, AML/CTF risks, and market integrity amid evolving EU frameworks like MiCA.

What Changed

This is a discussion paper and consultation, not binding legislation, so no immediate regulatory changes or requirements are imposed. Key discussion points include:
Defining DeFi based on decentralization criteria (e.g., automation, network architecture, governance, lack of single points of failure).
Distinguishing permissioned vs. permissionless protocols and public vs. private blockchains.
Regulatory approaches to smart contracts (e.g., certification, varying responsibilities), open-source code, and governance.
Adopting IOSCO recommendations: identify responsible persons (developers, DAOs), enforce risk management, disclosures, conflict-of-interest mitigation, and applicable laws.

Suggested Considerations

Submit feedback (past deadline): Stakeholders could contribute by September 30, 2023, to innovation@amf-france.org.
Monitor developments: Track AMF/ACPR follow-ups, including smart contract certification discussions.
Conduct internal assessments: Analyze DeFi exposures using IOSCO criteria—identify responsible persons, risks (operational, AML/CTF), interconnections with TradFi, and ensure disclosures/conflict management.
Enhance compliance programs: Prepare for proportionate rules on governance, cybersecurity, solvency, transparency; align with "same risk, same regulation" for DeFi-like activities.
Engage stakeholders: Participate in AMF ecosystem dialogues at French/EU/international levels.

Key Dates

June 19, 2023

- AMF publishes initial discussion paper on DeFi regulatory issues

September 30, 2023 DEADLINE

- Deadline for stakeholder contributions to the discussion paper

July 10, 2024

- AMF publishes summary of responses to the discussion paper

Compliance Impact

Urgency: Medium – This is non-binding consultation feedback without hard deadlines or rules, but it previews AMF's regulatory trajectory toward DeFi oversight, including AML/CTF enforcement and investor safeguards, amid MiCA rollout. It matters because DeFi's growth amplifies risks like pseudonymity-driven financial crime and market abuse, potentially triggering enforcement of existing laws; firms risk non-compliance if unprepared for "same risk, same regulation" application, especially with AMF's international push.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

Topics:

Authorisation & Licensing AML / Financial Crime Consumer Protection / Conduct

FintechCrypto ExchangeAll Firms

🇫🇷 AMF Enforcement high

May 24th 2023

The AMF Enforcement Committee sanctions an asset management company and two of its managers for breaches of their professional obligations

Sanctions & settlements Asset management Journalists Investment management companies The AMF Enforcement Committee sanctions an asset management company and two of its managers for breaches of their professional obligations

AI Analysis

The AMF Enforcement Committee sanctioned asset management company M Capital Partners and its managers Rudy Secco (€70,000 fine) and Stéphanie Minissier (€35,000 fine) with a total firm fine of €200,000 in its decision dated 31 December 2025, for multiple breaches of professional obligations spanning August 2019 to December 2023. This case underscores AMF's strict enforcement on operational compliance, scope of authorized activities, and AML/CFT systems in asset management, serving as a critical reminder for firms to ensure robust, traceable processes and manager accountability. It matters because it highlights personal liability for senior managers and recurring AMF focus on tied agents exceeding permitted services, potentially signaling increased scrutiny in 2026.

What Changed

This is an enforcement decision, not a new regulation, but it reinforces and clarifies existing requirements under French Monetary and Financial Code (e.g., Article L.
Asset management companies (AMCs) acting as tied agents cannot provide placement of financial instruments without a firm commitment basis, as this exceeds the restrictive list of permitted investment...
Investment allocation processes must be precise, operational, and traceable, with demonstrated compliance to investment procedures.
Firms must maintain effective systems for conflicts of interest identification/prevention, AML/CFT (including adequate due diligence), and overall operational controls. These align with patterns in...

Suggested Considerations

Review and enhance tied agent activities to ensure no unauthorized investment services like non-firm commitment placements; map against permitted services list.
Audit investment allocation systems for precision, operationality, and traceability; implement verifiable verifications.
Strengthen AML/CFT frameworks: ensure due diligence is adequate, systems are operational, and staff training is regular.
Update conflicts of interest policies with clear identification, prevention, and management procedures.
Conduct senior manager attestations on personal oversight; perform gap analysis against this and similar cases (e.g., Eres Gestion, Inter Gestion).

Key Dates

August 2019

December 2023; - Period of breaches investigated

31 December 2025

- AMF Enforcement Committee decision date; fines imposed on M Capital Partners (€200,000), Rudy Secco (€70,000), and Stéphanie Minissier (€35,000)

Compliance Impact

Urgency: High - This recent (Dec 2025) decision directly implicates senior accountability and operational failures in core AMC functions, with fines totaling €305,000 showing AMF's willingness to penalize both firms and individuals. It matters amid a pattern of similar sanctions (e.g., €200k on Eres in 2023 for procedures/investor info; warnings/fines on Inter Gestion in 2024 for AML), indicating heightened 2026 enforcement risk; non-compliant firms risk fines, reputational damage, and manager bans, especially if dually registered.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

AML / Financial Crime Senior Managers / Governance Consumer Protection / Conduct

Topics:

Asset Manager

🇫🇷 AMF Enforcement high

May 16th 2023

The AMF Enforcement Committee fines a portfolio asset management company for breaches of its professional obligations

Sanctions & settlements Journalists Investment management companies The AMF Enforcement Committee fines a portfolio asset management company for breaches of its professional obligations

AI Analysis

The AMF Enforcement Committee fined portfolio asset management company M Capital Partners €200,000, and its directors Rudy Secco (€70,000) and Stéphanie Minissier (€35,000) on 31 December 2025, for multiple breaches spanning August 2019 to December 2023, including unauthorized placement of financial instruments as a tied agent, non-operational investment allocation processes, inadequate compliance with investment procedures, deficient conflicts of interest management, and non-operational AML/CFT systems. This decision underscores AMF's strict enforcement of operational compliance and scope limitations for asset managers, serving as a critical reminder for firms to ensure robust, traceable systems and director accountability. It matters because it highlights personal liability for managers and recurring AMF focus on AML/CFT and procedural deficiencies, potentially signaling increased scrutiny in 2026.

What Changed

This is an enforcement action, not a regulatory change introducing new rules. It reinforces existing obligations under French financial regulations (e.g., Monetary and Financial Code) for asset...
Strict limits on services: AMCs cannot provide placement of financial instruments without a firm commitment basis, even as tied agents; doing so circumvents authorized investment services.
Operational investment systems: Processes for allocating investments between funds must be precise, with full traceability of verifications.
Conflicts of interest: Firms must identify, prevent, and manage conflicts effectively.
AML/CFT: Systems must be fully operational, with adequate due diligence (e.g., client identification, PEP screening).

Suggested Considerations

Audit dual roles: Review tied agent activities to ensure no unauthorized placement services; cease any circumvention of AMC service restrictions.
Enhance investment processes: Implement precise, operational rules for fund investment allocation, with full traceability of due diligence and verifications.
Strengthen controls: Update conflicts of interest frameworks, AML/CFT systems (including due diligence, training, and risk assessments), and compliance monitoring to ensure operational effectiveness.
Director oversight: Responsible managers must demonstrate active supervision; conduct gap analyses attributing breaches to governance failures.
Documentation: Maintain auditable records for all procedures; test systems for operationality via internal audits.

Key Dates

August 2019

December 2023; - Period of breaches investigated

31 December 2025

- AMF Enforcement Committee decision date; fines imposed on M Capital Partners, Rudy Secco, and Stéphanie Minissier

Compliance Impact

Urgency: High - This recent (Dec 2025) decision aligns with a pattern of AMF fines on AMCs for AML/CFT, procedural, and operational failures (e.g., €200k on Eres Gestion in 2023 for rebates/investments; warnings/fines on Inter Gestion REIM in 2024 for AML). It matters due to director liability, escalating fines (up to €200k+), and AMF's educational role in clarifying regulations, risking similar actions for non-compliant firms in 2026 amid AIFMD 2.0 focus.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

AML / Financial Crime Authorisation & Licensing Senior Managers / Governance

Topics:

Asset Manager

Consumer Protection / Conduct AML / Financial Crime

🇫🇷 AMF Enforcement high

May 3rd 2023

The AMF Enforcement Committee fines a portfolio asset management company and its manager for breaches of their professional obligations

Sanctions & settlements Asset management Compliance Anti-money Laundering Executive & other private individuals Investment management companies The AMF Enforcement Committee fines a portfolio asset management company and its manager for breaches of their...

AI Analysis

The AMF Enforcement Committee fined portfolio asset management company M Capital Partners €200,000 and its managers Rudy Secco (€70,000) and Stéphanie Minissier (€35,000) on 31 December 2025 for multiple breaches of professional obligations from August 2019 to December 2023, including unauthorized investment services as a tied agent, non-operational investment allocation processes, deficient conflict-of-interest management, and inadequate AML/CFT systems. This decision underscores AMF's strict enforcement against operational failures in asset management, particularly for firms balancing portfolio management with tied agent roles, emphasizing personal accountability for managers. Compliance teams must review this for gaps in procedures, as it highlights how imprecise processes and poor traceability lead to substantial sanctions.

What Changed

This is an enforcement decision, not a new regulation, but it reinforces existing AMF requirements under French Monetary and Financial Code (e.g., Article L. 214-24-1) for asset managers:
Asset management companies (sociétés de gestion) are restricted to specific investment services; providing placement of financial instruments without firm commitment (as a tied agent) circumvents...
Investment systems must be operational with precise allocation rules between funds; lack of traceability in verifications violates due diligence obligations.
Firms must maintain effective conflict-of-interest identification, prevention, and management processes.
AML/CFT systems require operational due diligence, including adequate client and asset verification; deficiencies here trigger sanctions. These align with prior AMF positions but clarify enforcement...

Suggested Considerations

Audit investment services scope to ensure no unauthorized placement activities, especially if acting as tied agents; cease and remediate any circumventions.
Enhance investment allocation processes with precise rules, full traceability of verifications, and demonstrable operationality.
Strengthen conflict-of-interest frameworks with identification, prevention, and management protocols, including documentation.
Overhaul AML/CFT systems for effective due diligence on clients, assets, and risks; conduct staff training and test operationality.
Review manager accountability: responsible managers should self-assess oversight of compliance functions.

BankWealth Manager

Investment Management Capital Markets & Trading Wealth & Private Banking

🇫🇷 AMF Enforcement high

December 23rd 2022

The AMF Enforcement Committee fines a portfolio asset management company for breaches of its professional obligations

Sanctions & settlements Journalists Investment management companies The AMF Enforcement Committee fines a portfolio asset management company for breaches of its professional obligations

AI Analysis

The AMF Enforcement Committee imposed a €150,000 fine on **Inocap Gestion**, a portfolio asset management company, for multiple operational and compliance failures between 2022 and the enforcement decision date. This case demonstrates the AMF's enforcement priorities around liquidity risk management, market abuse detection systems, and anti-money laundering (AML/CFT) procedures—critical control areas that asset managers must operationalize effectively to avoid substantial penalties.

What Changed

The decision does not introduce new regulatory requirements but rather clarifies enforcement expectations for existing obligations:
Liquidity Risk Management: Asset managers must establish procedures that are both adequate in design and operational in practice, not merely documented
Market Abuse Detection Systems: Surveillance systems must specify conditions for participation in market surveys and establish clear consequences for non-compliance
AML/CFT Procedures: Risk mapping and client onboarding procedures must be sufficiently detailed to identify and assess money laundering risks, including beneficial owner identification and...
Compliance Function: The compliance and internal control officer must actively centralize and monitor information on market abuse across the organization

Suggested Considerations

assessments across these areas:
*Liquidity Risk Management: Review procedures for adequacy and operational effectiveness; ensure they address fund-specific liquidity profiles and stress scenarios
*Market Abuse Detection: Audit surveillance systems to confirm they specify participation conditions in market surveys and document consequences for violations
*AML/CFT Compliance: Enhance risk mapping to capture money laundering typologies; strengthen client onboarding procedures to verify beneficial owners and screen for PEPs
*Compliance Monitoring: Establish centralized processes for the compliance officer to aggregate and review market abuse information across all business lines

Key Dates

21 December 2022

- Enforcement Committee decision date against Inocap Gestion

No specific implementation deadline stated DEADLINE

- The decision addresses historical breaches; however, firms should immediately remediate similar deficiencies

Compliance Impact

Urgency: HIGH

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

Topics:

AML / Financial Crime Market Abuse / Surveillance Operational Resilience / Outsourcing

Asset ManagerWealth Manager

Banking & Credit Investment Management Insurance & Pensions Capital Markets & Trading Payments & E-Money Crypto & Digital Assets

🇮🇪 CBI Enforcement low

October 6th 2022

Insurance supervision in an uncertain environment - Remarks by Domhnall Cullinan, Director of Insurance Supervision, at Financial Services Ireland

Introduction Good morning everyone. Thank you for inviting me to speak here today. Before I begin, I’d like to acknowledge the important role played by Financial Services Ireland in advocating for its members, and in promoting the Irish financial services sector, both here and abroad. Whilst the respective missions we undertake are undoubtedly different, we have a shared interest in a strong and stable financial services sector. It is claimed that the phrase “may you live in interesting times...

Sectors:

Topics:

AML / Financial Crime Consumer Protection / Conduct Prudential / Capital Requirements

Insurance

🇫🇷 AMF News high

September 28th 2022

AMF and ACPR announce the withdrawal of BYKEPS SAS’s registration as a DASP

Crypto-assets Anti-money Laundering Supervision Journalists Investment services providers AMF and ACPR announce the withdrawal of BYKEPS SAS’s registration as a DASP

Sectors:

Topics:

Crypto Exchange

Investment Management Wealth & Private Banking Banking & Credit

🇮🇪 CBI Enforcement medium

September 26th 2022

Central Bank of Ireland Issues Warning on Unauthorised Firm – Fraudulent entity clones authorised firm SEI Investments

It has come to the attention of the Central Bank that a scam entity by the name SEI Investment (United States, Ireland), formerly operating the fraudulent clone website www.seiinvestment.com, has been claiming to be an investment firm / investment business firm in the absence of appropriate authorisations. In this instance, the scam entity cloned details and website content of the legitimate firm, SEI Investments (www.seic.com), in order to deceive consumers. The legitimate firm was proactive...

AI Analysis

The Central Bank of Ireland (CBI) issued a warning on 26 September 2022 about a fraudulent entity named "SEI Investment (United States, Ireland)" that cloned the legitimate authorised firm SEI Investments (www.seic.com) via the fake website www.seiinvestment.com to deceive consumers into unauthorised investment services. This matters because it highlights the rising threat of clone firm scams, which impersonate authorised entities using stolen details like names, addresses, and authorisation numbers, exposing firms to reputational risk and consumers to financial loss without Investor Compensation Scheme protection. Authorised firms must remain vigilant in monitoring for clones and reporting them promptly, as demonstrated by SEI Investments' proactive response that led to the site's deactivation in February 2022.

What Changed

This is not a regulatory change or new requirement but a public enforcement warning under Section 53 of the Central Bank (Supervision and Enforcement) Act 2013, emphasising ongoing enforcement against unauthorised firms providing regulated financial services, which is a criminal offence. It reinforces consumer protection guidance without introducing new rules, but signals CBI's heightened focus on clone firm frauds, as seen in similar warnings (e.g., The Capital Holdings clone, Bank of Ireland clones).

Suggested Considerations

Monitor for clones: Regularly search for impersonations of your firm's name, website, authorisation numbers, LEI, CRO, or address; report suspicions to CBI at (01) 224 4000.
Client communications: Advise clients to always access CBI Register directly from www.centralbank.ie (not via email/website links), double-check URLs/phone numbers, verify products on legitimate sites, and apply the SAFE test for unsolicited contacts.
Internal processes: Update fraud awareness training, client onboarding checks, and surveillance for clone activity; emulate SEI Investments by proactively notifying authorities.
Public reporting: Encourage staff/clients to report unauthorised activity via CBI hotline or Search Unauthorised Firms page.

Key Dates

February 2022

- Fraudulent clone website www.seiinvestment.com deactivated following legitimate firm's report

26 September 2022

- CBI issues warning notice on SEI Investment clone

Compliance Impact

Urgency: Medium – Not critical as the specific clone site was deactivated in 2022, but medium due to persistent clone fraud trend evidenced by ongoing CBI warnings into 2026 (e.g., BW Financial Services clone in August 2025, Stalwart Investments clone in March 2026). Matters for authorised firms as it underscores reputational, operational resilience, and consumer protection obligations under CBI's supervisory framework; unaddressed clones can lead to client complaints, enforcement scrutiny, or compensation claims if mis-sold products are linked back erroneously.

References

AI-generated analysis. May contain errors or omissions — verify with the original CBI source before acting. Full disclaimer.

Sectors:

Topics:

Consumer Protection / Conduct AML / Financial Crime Authorisation & Licensing

Asset ManagerWealth ManagerBank

🇫🇷 AMF Enforcement high

July 18th 2022

The AMF Enforcement Committee fines a portfolio asset management company for breaches of its professional obligations

Sanctions & settlements Journalists The AMF Enforcement Committee fines a portfolio asset management company for breaches of its professional obligations

AI Analysis

The AMF Enforcement Committee fined an unnamed portfolio asset management company €400,000 for multiple breaches of professional obligations, including non-operational investment/divestment procedures, inadequate conflict of interest management with group service providers, lack of transparency on distributor fee retrocessions, deficient client categorization, and weak AML/CFT due diligence. This enforcement action, mirroring recent similar cases against firms like Novaxia Investissement and Eternam, underscores the AMF's heightened scrutiny on operational robustness and transparency in asset management, serving as a critical reminder for firms to ensure procedures are fully implemented and documented to avoid personal liability for executives.

What Changed

This is an enforcement decision rather than new legislation, but it reinforces and clarifies existing regulatory requirements under AMF professional obligations for portfolio asset managers (sociétés...
Investment/divestment processes must be fully operational, with traceability of compliance checks against fund policies and formalized due diligence before allocations.
Effective conflicts of interest policies are mandatory when using group service providers, with comprehensive, accurate investor disclosures on related remuneration.
Full transparency required on retrocessions of management fees to distributors, including justification of added value.
Robust client categorization and AML/CFT systems, including operational procedures, risk mapping, and adequate due diligence on fund assets/liabilities. No explicit regulatory changes, but these...

Suggested Considerations

Audit internal procedures: Immediately review investment/divestment, valuation, and allocation processes for operational status, completeness, traceability, and documentation of due diligence.
Enhance conflict and transparency controls: Implement/test effective conflicts of interest policies for group providers/distributors; update investor disclosures on fees/retrocessions with clear justifications.
Strengthen AML/CFT and client categorization: Validate risk mapping, procedures, and due diligence; ensure formalization of independent valuer work and external expert oversight.
Senior manager accountability: Conduct gap analysis attributing responsibilities; train executives on personal liability risks.
Mock AMF inspections: Simulate Enforcement Committee reviews, focusing on evidence of procedure adherence.

Key Dates

9 September 2025

- AMF Enforcement Committee decision fining Eternam €400,000 (similar case on marketing, club deals, conflicts, valuation, AML/CFT)

10 December 2025

- AMF Enforcement Committee decision fining Novaxia Investissement €400,000 and director €100,000 (investment processes, group providers, distributor fees, client categorization, AML/CFT)

31 December 2025

- AMF Enforcement Committee decision fining M Capital Partners €200,000 and directors €70,000/€35,000 (investment systems, conflicts, AML/CFT)

Compliance Impact

Urgency: High - Recent cluster of identical fines (€200k-€500k total per case) in late 2025 signals AMF's enforcement priority on operational deficiencies in asset management, with personal sanctions escalating risks for leadership. Firms with similar setups (group providers, AIFs/club deals) face imminent inspection risk; non-compliance could trigger fines, reputational damage, and appeals processes.

References

AI-generated analysis. May contain errors or omissions — verify with the original AMF source before acting. Full disclaimer.

Sectors:

AML / Financial Crime Consumer Protection / Conduct Senior Managers / Governance

Topics:

Asset Manager

Investment Management Banking & Credit Wealth & Private Banking

🇫🇷 AMF News medium

April 4th 2022

The AMF and TRACFIN sign a new cooperation protocol

Anti-money Laundering Asset management The AMF and TRACFIN sign a new cooperation protocol

Sectors:

Topics:

AML / Financial Crime Authorisation & Licensing Reporting & Disclosure

Asset ManagerBankWealth Manager

Consumer Protection / Conduct AML / Financial Crime Authorisation & Licensing

🇫🇷 AMF Enforcement high

December 29th 2021

The AMF Enforcement Committee fines an asset management company for several breaches of its professional obligations

Sanctions & settlements Journalists The AMF Enforcement Committee fines an asset management company for several breaches of its professional obligations

AI Analysis

The AMF Enforcement Committee fined asset management company Altaroc Partners €600,000 and its senior managers Maurice Tchenio (€500,000) and Patrick de Giovanni (€200,000) on 15 September 2025 for multiple breaches of professional obligations, including lack of operational procedures for fund investments/divestments, inadequate AML/CFT due diligence, unproven benefits of fee retrocessions to distributors, and shortcomings in marketing materials. This decision underscores AMF's focus on operational controls, due diligence, and transparency in asset management, serving as a key enforcement precedent that highlights personal liability for senior managers. Compliance teams must review it to strengthen internal procedures and governance amid rising AMF scrutiny on these issues.

What Changed

This is an enforcement action, not a regulatory change introducing new rules; it enforces existing obligations under French financial regulations for asset management companies (sociétés de gestion...
Absence of operational procedures for investment/divestment processes, failing to verify lender authorizations, breaching duties to act honestly, fairly, professionally, with skill, care, and...
Inability to demonstrate that retrocessed management fees to distributors improved client services.
Failure to systematically perform AML/CFT due diligence on fund assets and liabilities.
Shortcomings in fund marketing materials, lacking clear, accurate information. These align with ongoing AMF expectations for robust internal systems, as seen in similar cases emphasizing operational...

Suggested Considerations

Implement and document operational procedures for all investment/divestment processes, including third-party authorization checks (e.g., lenders).
Conduct and document systematic AML/CFT due diligence on fund assets/liabilities, ensuring risk mapping and procedures are operational.
Substantiate retrocessions of fees to distributors with evidence of enhanced client services; otherwise, cease or disclose fully.
Review and enhance fund marketing materials for accuracy, comprehensiveness, and non-misleading content.
Senior managers: Demonstrate oversight of compliance functions; conduct gap analyses attributing breaches.

Key Dates

Topics:

BankWealth ManagerFintech